ASHA Issues Public Comment on Transparency in Coverage

American Speech-Language-Hearing Association

President Theresa Rodgers addresses CMS’ proposed rule

Editor’s note: The following is taken from a February 7 speech. To see the full text, visit here.

On behalf of the American Speech-Language-Hearing Association, I write to offer comments on the Transparency in Coverage proposed rule.

The American Speech-Language-Hearing Association (ASHA) is the national professional, scientific, and credentialing association for 204,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students.

ASHA appreciates the Centers for Medicare & Medicaid Services’ (CMS’s) efforts toward improving health care transparency across settings and payers. ASHA supports: 1) improving consumers’ access to meaningful information on the price of their care, and; 2) protecting consumers from unexpected financial exposure. However, many of the proposals in the Transparency in Coverage proposed rule, while well-intended, may not adequately address concerns such as reducing surprises in relation to consumers’ out-of-pocket (OOP) costs and providing relevant price and benefit information to enable consumers to make cost-conscious decisions.

This letter includes ASHA’s comments on the following topics discussed in the Transparency in Coverage proposed rule:

* Out-of-Network Allowed Amount and Disclosure Notice

* First Delivery Method: Internet-Based Self-Service Tool

* Public Disclosure of Negotiated Rates and Historical Out-of-Network Allowed

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