TMA Advocacy Comment Letters

TMA Advocates for Texas Physicians

 

TMA advocates on behalf of physicians and medical students at the state and federal level year round. Our goal is improve physicians' practice viability, reduce the hassles of patient care, and protect the patient-physician relationship. Here are the many letters TMA has sent to state and federal leadership.

2024 Comment Letters and Testimony

FEDERAL

Cybersecurity

Testimony by Adam Bruggeman, MD, to the U.S. House Energy and Commerce Committee Regarding Health Sector Cybersecurity After Change Healthcare Attack (April 16, 2024)

Health Information Technology

TMA Comment Letter to the Assistant Secretary for Technology Policy on Health Data, Technology, and Interoperability proposed regulations (Oct. 1, 2024)

TMA Comment Letter to the Agency for Healthcare Research and Quality Re: CDS Connect RFI posted to the Federal Register (July 23, 2024)

TMA Comment Letter to the Office of the National Coordinator Re: United States Core Data for Interoperability Draft Version 5 (April 8, 2024)

Payment

Comment Letter From Medical Societies Urgently Requesting Congressional Leaders to Pass Legislation to Both Prevent the Scheduled 2.83 Percent Medicare Physician Payment Cut and, Provide a Positive Payment Update for 2025 (Nov 15, 2024)

TMA Comment Letter to CMS on the Proposed 2025 Medicare Physician Fee Schedule (Sep. 6, 2024)

Comment Letter From Medical Societies urging Congress to prioritize and advance several key bills and legislative proposals that provide greater fiscal stability for physicians and reform key elements of the Medicare Access and CHIP Reauthorization Act (MACRA). (July 24, 2024)

TMA Comment Letter to the Ways and Means Committee Regarding the Collapse of Independent Payment Practice (June 6, 2024)

TMA Letter to Senators Cornyn for a Senate Finance Hearing on Chronic Care/Medicare Physician Payments (April 11, 2024)

TMA Letter to Senators Cornyn and Cruz calling for a reverse to the 2024 Medicare Physician Payment Cut (Feb. 22, 2024)

Comment Letter From Medical Societies: Strongly Urging Congress to Quickly Pass Legislation to Reverse the 3.37 Percent Medicare Physician Payment Cuts That Took Effect On Jan. 1, 2024 (Jan. 17, 2024)

Scope

Comment Letter From Medical Societies to Congress opposing bills that would inappropriately allow pharmacists to perform services that would otherwise be covered if they had been furnished by a physician, test and treat patients for certain illnesses and expand Medicare payment for pharmacists in limited but significant ways (July 23, 2024)

Surprise Billing

TMA Comment Letter by President Rick W. Snyder II, MD, to the U.S. House Ways and Means Committee regarding Access to Health Care in America: Ensuring Resilient Emergency Medical Care (March 18, 2024)

TMA Comment Letter to U.S. Department of Health and Human Services: Re: RIN 0938-AV15 (Federal Independent Dispute Resolution Operations Proposed Rule) (Jan. 2, 2024)

STATE

Abortion

TMA Supplemental Comments Regarding Texas Medical Board Proposed Rules on Medical Exceptions Relating to Abortions (June 17, 2024)

TMA Comments Regarding Texas Medical Board Proposed Rules on Medical Exceptions Relating to Abortions (May 4, 2024)

Graduate Medical Education / Workforce

TMA Comment Letter to the Texas Higher Education Coordinating Board Regarding Rural Resident Physician Grant Program (June 25, 2024)

Health Information Technology

TMA Comment Letter to State Rep. Giovanni Capriglione Re: Artificial Intelligence Regulation | AI Stakeholder Feedback
(March 8, 2024)

Insurance

TMA Comment Letter to Texas Department of Insurance Regarding Multiple Employer Welfare Arrangements (June 3, 2024)

TMA and Association Comment Letter to Texas Department of Insurance RE: PPO and EPO Rule Proposal (Jan. 22, 2024)

Medicaid

TMA, Stakeholders Seek Texas HHS Fixes for Medicaid Physician/Provider Enrollment System (Comment Letter to the Texas Health and Human Services Commission Regarding Medicaid PEMS, Nov. 1, 2024)

TMA Comment Letter to the Texas Health and Human Services Commission OIG Regarding Proposed Rule #23R031, Recoupment of Overpayments Identified by Inspection (July 15, 2024).

Payment

TMA, TSA, TxSCO Letter to HHSC in Response to Proposed Medicaid Payment Rates for the Medicaid Biennial Calendar Fee Review (Nov 12, 2024)

Public Health

TMA Offers Improvements to Law Prohibiting Employers From Imposing Coronavirus Vaccine Mandates (TMA Comment Letter by President G. Ray Callas, MD, to the Texas Workforce Commission Regarding Rules RE: Prohibited COVID-19 Vaccine Mandates by Private Employers, Nov. 4, 2024.)

Texas Tobacco Control Coalition Letter to the Legislative Budget Board Supporting DSHS Tobacco-Related Budget Recommendations (Oct. 3, 2024)

Texas Women's Healthcare Coalition Comments to Texas Legislative Budget Board on 2026-27 Funding for Women's Health Programs (Sept. 30, 2024)

TMA Written Comments Seeks Community Voice on MMMRC, Data-Sharing with CDC (TMA Written Comments to Texas Maternal Mortality and Morbidity Review Committee, Sept. 27, 2024)

TMA Comment Letter to the Texas Department of State Health Services Re: Proposed Revisions to the State’s Emergency Medical System and Trauma Care Rules (Sept. 3, 2024)

TMA Comment Letter to the Texas Department of State Health Services Concerning Proposed Rule #23R011, Regarding Radiation Control (July 15, 2024).

TMA and TPS Comments to HHSC Regarding Draft Rule 24R058 (HB 44) (June 25, 2024)

TMA Comment Letter to the Texas Health and Human Services Commission Regarding State Hospital Essential Caregiver Designation (June 3, 2024)

TMA Comment Letter to Texas Department of State Health Services RE: Proposed Trauma Designation Rules 21R151 (Feb. 16, 2024)

Scope of Practice

TMA Comment Letter to Texas Health and Human Services RE: Proposed Rule 22R054 (Jan. 22, 2024)

TMA Comment Letter to Texas Board of Nursing RE: SB 1343 Implementation (Jan. 21, 2024)

2023 Comment Letters

FEDERAL

Health Information Technology

TMA Comment Letter to the ONC RE: 21st Century Cures Act: Establishment of Disincentives for Health Care Providers That Have Committed Information Blocking Proposed Rule (Dec. 20, 2023)

 TMA Comment Letter to the Federal Trade Commission (FTC) Re: Health Breach Notification Proposed Rule (Aug. 8, 2023)

TMA Comment Letter to the Office of the National Coordinator on HIT Re: Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing Proposed Rule (June 20, 2023)

TMA Comment Letter to the Office of the National Coordinator (ONC) for Health Information Technology Re: United States Core Data for Interoperability Draft Version 4 (Apr. 17, 2023)

TMA Comment Letter to the DEA Re: Telemedicine Prescribing of Controlled Substances Without In-Person Evaluation (Mar. 31, 2023)

TMA Comment Letter to DEA Re: Buprenorphine Via Telemedicine Encounter (Mar. 31, 2023)

TMA Comment Letter to CMS Re: Advancing Interoperability and Improving Prior Authorization (Mar. 13, 2023)

Comment Letter from the Telehealth Coalition to HHS and DHS Re: Telehealth Policies (Jan. 26, 2023)

TMA Comments to HHS Re: National Council for Prescription Drug Programs (NCPDP) Pharmacy Standards (Jan. 9, 2023)

Insurance

TMA Comments on Proposed Rules Concerning Short-Term, Limited Duration Insurance (Sept. 11, 2023)

Payment

Comment Letter Supporting Coverage for the Surveillance Colonoscopy That Patients Need After Having Precancerous Polyps or Lesions Removed During an Initial Colorectal Cancer Screening Test (Dec. 7 2023)

Comment Letter From Medical Societies to Senate and House Leadership Calling on Congress to Prevent the 3.37 Percent Medicare Physician Payment Cut on January 1. (Nov. 16, 2023)

Comment Letter From Medical Societies to House of Representatives Members Regarding Their Proposal to Reform the Budget-Neutrality Policies in Medicare Physician Payments (Oct. 31, 2023)

TMA Comment Letter to CMS on the Proposed 2024 Medicare Physician Fee Schedule (Sep. 8, 2023)

Comment Letter from Medical Societies to Congressional Representatives Supporting HR 2474 Re: Strengthening Medicare for Patients and Providers Act (Apr. 19, 2023)

Comment Letter from Medical Societies to Cigna Re: Correct Use of Modifier 25 (Apr. 18, 2023)

Comment Letter from Medical Societies to Congressional Leaders Urging Fiscal Stability by Passing Legislation that Provides an Annual Inflation-based Payment Update Based on the Full Medicare Economic Index (MEI) (Mar. 15, 2023)

Prior Authorization

Multi-Organizational Letter to United Health Care Re: Gastrointestinal (GI) Endoscopy Prior Authorization Program (May 8, 2023)

Comment Letter from Medical Societies to CMS on Proposed Meaningful Prior Authorization Reforms in the Part C & Part D Proposed Rule (Feb. 13, 2023)

Scope of Practice

Comment Letter to Congress Re: Opposition to the Improving Care and Access to Nurses AcH HR2713 (“I CAN Act" H.R. 2713) (June 1, 2023)

STATE

Insurance

TMA Comment Letter to the Texas Department of Insurance re: Rulemaking Regarding Prompt Pay Deadline Extensions (Nov. 6, 2023)

2022 Comment Letters

FEDERAL

Corporate Practice of Medicine

TMA Comment Letter to CMS on Doctors Hospital at Renaissance (March 11, 2022)

Compliance

TMA Comment Letter to the National Institute for Occupational Safety and Health RE: Improve Care Environment to Reduce Burnout (Jan. 24, 2022)

Health Information Technology

TMA Comment Letter to CMS Re: National Directory of Healthcare Providers (Dec. 6, 2022)

TMA Comment Letter to The Sequoia Project’s Data Usability Workgroup Re: Its Implementation Guide (Oct. 14, 2022)

TMA Letter to HHS Urging the Delay of Oct. 6 Full Implementation of the 21st Century Cures Act Interoperability and Information Blocking Regulations. (Sept. 29, 2022)

TMA Comment Letter to The Joint Commission and Centers for Medicare & Medicaid Services (CMS) RE: Physician Orders via Secure Text Messaging (May 12, 2022)

TMA Comment Letter to the ONC Re: USCDI v3 (Apr. 27, 2022)

Payment

Comment Letter to U.S. House and Senate Leadership Re: Medicare Payment Rates (Dec. 8, 2022)

TMA Comment Letter to CMS Re: 2023 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule (Sept. 6, 2022)

TMA Comment Letter Re: Immediate Relief from Medicare Physician Payment Cuts Needed (June 27, 2022)

TMA Letter to Congress Re: Relief from Medicare Sequester Payment Cut Needed Before Apr. 1, 2022 (Mar. 10, 2022)

Prior Authorization

TMA Comment Letter to the ONC Re: Request for Information: Electronic Prior Authorization Standards, Implementation Specifications, and Certification Criteria (Mar. 25, 2022)

Public Health

TMA Comment Letter to National Committee on Vital and Health Stats Request for Public Comment on Proposals for Updates to X12 Transactions and New and Updated CORE Operating Rules (Dec. 14, 2022)

TMA Comment Letter to the FDA Re: Cigar Flavors (July 8, 2022)

TMA Comment Letter to the FDA Re: Menthol in Cigarettes (July 8, 2022)

Quality Reporting

TMA Comment Letter to Representative Colin Allred Re: Small Practice, Underserved, and Rural Support Program Extension Act of 2022 (SURS Extension Act) (Feb. 14, 2022)

TMA Comment Letter to Senator Cornyn Re: Small Practice, Underserved, and Rural Support Program Extension Act of 2022 (SURS Extension Act) (Feb. 14, 2022)

Social Determinants of Health

TMA Comment Letter Re: Public Comment on Drivers of Health Measures & Advance Investment Payments (Sept. 6, 2022)

TMA Comment Letter to CMS Re: Social Determinants of Health (Jan. 13, 2022)

STATE

Comment Letter to TDI Re: Standard Prior Authorization Form Change (March 28, 2022)

Comment Letter Re: The 88th Senate Legislative Interim Study Proposals (Feb. 2022)

2021 Comment Letters

FEDERAL

COVID

TMA Comment Letter to CMS RE: Requested Feedback on Medicare and Medicaid COVID-19 Public Health Emergency Flexibilities (Oct. 26, 2021)

Comment Letter to the U.S. Department of Labor RE: Concerns with Compliance Costs Associated with the OSHA Occupational Exposure to COVID-19; Emergency Temporary Standard (Aug. 20, 2021)

Comment Letter to Aetna RE: Implement and Pay for CPT Code 99072 and Reimbursement for Rapid COVID-19 Tests (Mar. 1, 2021)

Comment Letter to Anthem RE: Implement and Pay for CPT Code 99072 and Reimbursement for Rapid COVID-19 Tests (Mar. 1, 2021)

Comment Letter to BCBS RE: Implement and Pay for CPT Code 99072 and Reimbursement for Rapid COVID-19 Tests (Mar. 1, 2021)

Comment Letter to Cigna RE: Implement and Pay for CPT Code 99072 and Reimbursement for Rapid COVID-19 Tests (Mar. 1, 2021)

Comment Letter to UnitedHealthcare RE: Implement and Pay for CPT Code 99072 and Reimbursement for Rapid COVID-19 Tests (Mar. 1, 2021)

TMA Letter to the FCC RE: COVID-19 Telehealth Program Application Evaluation Metrics (Jan. 14, 2021)

Health Information Technology

Comment Letter to the CDC/National Center for Health Statistics RE: Request for Public Comment on Healthcare Standards Development, Adoption, and Implementation (Aug. 6, 2021)

TMA Comment Letter to the National Committee on Vital and Health Statistics (NCVHS) (July 30, 2021)

TMA Comment Letter: Expand Telemedicine to Enhance Health Care (Apr. 29, 2021)

TMA Comment Letter to the ONC RE: USCDI v2 for Interoperability (Apr. 15, 2021)

Healthcare Disparities

TMA Comment Letter: Inadequate Health Care Coverage Impacts Texans and Texas' Economy (Sept. 17, 2021)

TMA Comment Letter: Improve Maternal Health and Reduce Health Disparities (May 18, 2021)

Nomination/Recommendation Letters

TMA Letter to the Healthcare Systems Bureau Nominating Five Texas physicians to Serve on the Advisory Committee on Organ Transplantation (Sept. 15, 2021)

TMA Letter to the U.S. Government Accountability Office Nominating Ogechika Alozie, MD, MPH, to Serve on the Health Information Technology Advisory Committee (HITAC) (July 29, 2021)

TMA Letter to the National Center for Emerging Zoonotic Infectious Diseases/Centers for Disease Control and Prevention Recommending Emma L. Dishner, MD, MPH, for Appointment to the Infection Control Practices Advisory Committee (July 19, 2021)

Comment Letter to President Biden RE: Support for Richard Pan, M.D., for Health Resources and Services Administration (HRSA) Administrator (Apr. 15, 2021)

Payment

TMA Comment Letter to Representative Jodey Arrington RE: Medicare Physician Payment Cuts (Nov. 3, 2021)

TMA Thank You Letter to Representative Michael Burgess, MD, RE: Medicare Physician Payment Cuts (Nov. 3, 2021)

Comment Letter: Don't Make Physicians Pay to Get Paid (Oct. 14, 2021)

Thank You Letter to Congressman Tim Ryan RE: Inclusion of Language in the Report on the Implementation of the Medicare Appropriate Use Criteria (AUC) Program for Advanced Diagnostic Imaging (Sept. 17, 2021)

Thank You Letter to the U.S. House of Representatives Committee on Appropriations RE: Inclusion of Language in the Report on the Implementation of the Medicare Appropriate Use Criteria (AUC) Program for Advanced Diagnostic Imaging (Sept. 17, 2021)

Comment Letter to CMS Re: Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond Proposed Rules (July 28, 2021)

Comment Letter to UnitedHealthcare RE: Ongoing Concerns with the Retroactive Denial of Coverage of Emergency Level Care (June 29, 2021)

TMA Comment Letter to CMS and HHS RE: 2022 Hospital Inpatient Prospective Payment Systems Proposed Rule (June 25, 2021)

Comment Letter to UnitedHealthcare RE: New Policy to Allow for the Retroactive Denial of Coverage for Emergency Care (June 16, 2021)

TMA Comment Letter to to UnitedHealthcare RE: Impact of Incident-to Policy Changes (Apr. 27, 2021)

TMA Comment Letter to UnitedHealthcare RE: Incident-to Services Performed by Advanced Practice Nurses and Physician Assistants (Feb. 26, 2021)

Comment Letter to Speaker Pelosi, Majority Leader Schumer, Leader McConnell, and Leader McCarthy Re: Extending the Moratorium on Medicare Sequestration Until the End of the Public Health Emergency (Feb. 12, 2021)

Prescribing and Prior Authorization

Comment Letter by Healthcare Stakeholders Coalition to CMS RE: Prior Authorization (Apr. 7, 2021)

TMA Comment Letter to CMS on Payer APIs and Medicaid CHIP Prior Authorization Proposed Rule (Jan. 4, 2021) Read the TMT article. 

Quality Reporting

TMA Comment Letter to the National Quality Forum (NQF) RE: Texas Physicians Support Drivers of Health Quality Measures (Dec. 9, 2021)

TMA Comment Letter to Centers for Medicare and Medicaid Services (CMS) RE: Texas Physicians Support Drivers of Health Quality Measures (Dec. 9, 2021)

TMA Comment Letter to Urban Institute on Draft Developer-Reported Measures for the Electronic Health Record Reporting Program (Sept. 14, 2021)

TMA Comment Letter to CMS on the 2022 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule (Sept. 13, 2021)

TMA Comment Letter to CMS and HHS RE: 2022 Hospital Inpatient Prospective Payment Systems Proposed Rule (June 25, 2021)

Scope of Practice

Comment Letter to the U.S. Department of Veterans Affairs (VA) RE: the VA Supremacy Project (Dec. 16, 2021)

Comment Letter to the U.S. Department of Veteran Affairs RE: VA’s Efforts to Develop National Standards of Practice for Physicians and Other Health Professionals that Supersede State Scope of Practice and Licensure Laws (July 29, 2021) 

TMA Letter to Walgreens RE: Request for Walgreens Co.’s Policy on Communication with Customers (May 7, 2021)

Comment Letter to Department of Veterans Affairs on the Authority of VA Professionals to Practice Health Care (Jan. 7, 2021)

Surprise Billing

Comment Letter: Concerns with Interim Final Rule Requirements Related to Surprise Billing: Part II implementing the No Surprises Act (Nov. 17, 2021)

Comment Letter to the U.S. Department of Health and Human Services, U.S. Department of Labor, U.S. Department of the Treasury, Center for Medicare & Medicaid Services RE: the Interim Final Rules on the Requirements Related to Surprise Billing (Sept. 7, 2021)

Miscellaneous

Comment Letter to the U.S. Department of Education Requesting Amendments to Allow California and Texas Physicians to Receive Loan Forgiveness; Negotiated Rulemaking for Title IV Regulations Higher Education Act: Public Service Loan Forgiveness Program (July 1, 2021)

STATE

COVID

Comment Letter: Allocate ARPA Funds Strategically to Aid COVID-19 Recovery (Sept. 15, 2021)

Comment Letter to Texas Health and Human Services Commission RE: Insufficient Reimbursement for COVID-19 Tests (Feb. 16, 2021) 

Health Information Technology

Comment Letter: Preserve Safeguards to Treat Chronic Pain Via Telemedicine (Sept. 13, 2021)

Comment Letter: Upgrade Electronic Records Interoperability to Improve Patient Care (Sept. 9, 2021)

Licensure

Writing the Rules to Implement HB 3459
(Written comments by TMA on HB 3459 to Texas Dept. of Insurance, Sept. 30, 2021)

Payment

TMA Comment Letter to the Texas Department of Insurance (TDI) RE: Concerns About TRPN DirectPay as a Contracting Entity under Chapter 1458 of the Texas Insurance Code (Apr. 26, 2021)

TMA Comment Letter to Texas Department of Insurance RE: Proposed Rules on Mental Health and Substance Use Disorder Parity (Apr. 2, 2021)

Prescribing and Prior Authorization

Comment Letter: Smart Prior Auth Rulemaking Will Help Patients Access Timely Health Care (Sept. 20, 2021)

Comment Letter: Physicians Must Delegate and Supervise Prescribing Controlled Substances (Sept. 13, 2021)

Comment Letter: Physician Supervision and Delegation Must Control Prescribing (Mar. 18, 2021)

Workforce

Modernize the State's Public Health System and Enhance the Physician Workforce
(Written comments on Senate Bill 8 by TMA on Allocation of ARPA Funding, Oct. 4, 2021)

Miscellaneous

Comment Letter: to Texas Attorney General Ken Paxton RE: Gender-Affirming Care of Transgender Youth, RQ-0426-KP (Sept. 23, 2021)

Comment Letter: Curb Tobacco Use With Directed ARPA Fund Investment (Sept. 20, 2021)

Comment Letter: Banning Common Sense Protections Adversely Impacts Children’s Education (Aug. 30, 2021)

2020 Comment Letters

FEDERAL

COVID

TMA Comment Letter to Aetna, BCBS-TX, Humana, Cigna, and UHC RE: Extension of Annual Patient Deductible Renewals Due to COVID (Dec. 14, 2020)

TMA Comment Letter to HHS RE: Request for Withdrawal of the “SUNSET” Proposed Rule (Dec. 3, 2020)

TMA Comment Letter: Waive Budget Neutrality Requirements for a Year (Oct. 26, 2020)

Health Information Technology

TMA Comment Letter: Expand Access to Telemedicine and Access to Care (Oct. 9, 2020)

Payment

TMA Comment Letter to Senators Cornyn and Cruz RE: Need to Address 2021 Medicare Physician Payment Reductions (Dec. 4, 2020)

Comment Letter to CMS RE: Coverage of CPT Code 99072 (Nov. 10, 2020)

Comment Letter to Congressional Leaders on Delaying the Appropriate Use Criteria requirement (Nov. 7, 2020)

Comment Letter to BCBS-TX on Updating FDA Vaccine Prices in a Timely Manner (Nov. 6, 2020)

TMA Comment Letter to CMS RE: Medicare Program; CY 2021 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies of Proposed Rulemaking (Oct. 5, 2020)

Prescribing and Prior Authorization

TMA Comment Letter: Liberate Physician-Owned Hospitals, Moderate Prior Auth (Sept. 28, 2020)

TMA’s Comment Letter on the CMS Electronic Prescribing for Controlled Substances (EPCS) Request for Information (Sept. 25, 2020)

TMA Comment Letter to the DEA RE: Interim Final Rule on E-Prescribing of Controlled Substances (EPCS) (June 22, 2020)

Scope of Practice

Comment Letter: Only Physicians Should Be Called Physicians (Sept. 22, 2020)

Miscellaneous

TMA Comment Letter to UnitedHealth Group RE: Increase in Professional Liability Insurance Coverage (Dec. 4, 2020)

STATE

Payment

Comment Letter to Centene Corporation RE: Denying Payment for All Well Visits Using Modifier 25 (Dec. 23, 2020)