BAYCARE HEALTH SYSTEM

Advocated to the Domestic Policy Council around the inclusion of 1115 uncompensated care pool waiver days in the Medicaid numerator of the Medicare DSH percentage specifically as it pertains to 340B Drug Pricing Program qualification. Discussed key issues pertaining to Florida's Directed Payment Program and rules impacting state directed payment models. Advocated for the Improving Seniors Timely Access to Care Act to improve MA plan accountability. Advocated for parity to behavioral health reimbursement. Advocated for the importance of not-for-profit tax exempt status. Advocated broadly for reimbursement to improve food is medicine programs. Advocated for streamlined access to vital, innovative services such as Proton Therapy.

Opposed 340B rebate models and other policies to add burden and compliance to the 340B drug pricing program. Advocated against codification of a variety of price transparency provisions in the Patients Deserve Price Tags Act that exist in rule but will not meaningfully address healthcare affordability. Submitted comment letter on the Outpatient Prospective Payment System to CMS with concerns around site neutral reimbursement, 340B payment reductions, and 340B remedy clawback escalation to 3.0% annually.

Advocated for protection of the existing 340B drug pricing program and concerns around a rebate model at HRSA + general preservation of the 340B drug pricing program. Also discussed the concern around exclusion of section 1115 approved uncompensated care pool "waiver days" (low income pool days in Florida).