September 29, 2004
Attention NAMI Advocates:
On August 3, 2004, the Centers for Medicare and Medicaid Services (CMS) published the first set of draft regulations implementing the new Medicare prescription drug benefit. These regulations – over 1,300 pages in length – included a solicitation for comments from interested parties. When an agency such as CMS publishes such draft regulations, it carefully reviews comments and will often weigh the volume of comments in assessing whether or not to retain, delete or amend a provision in the rules. As a result, advocates (including NAMI) should make every effort to maximize the number of public comments supporting or opposing a particular perspective on a draft regulation. These draft rules on the Medicare drug benefit are no exception. Therefore NAMI National would like your state affiliate to consider submitting comments to CMS on the Medicare regulations.
Click here to read the current draft of NAMI National’s detailed comments to CMS on the draft rules. You are strongly encouraged to submit this document (or something very similar) to CMS. If you feel uncomfortable submitting the entire document, you may wish to submit comments the first three pages, which briefly summarize NAMI’s comments. IT IS IMPORTANT TO NOTE THAT THE DEADLINE FOR SUBMITTING COMMENTS IS CLOSE OF BUSINESS, MONDAY, OCTOBER 4.
Specific instructions for submitting comments are as follows:
1) If you want to mail your comments to CMS, you must send two copies and ensure that they are received by the agency no later than October 4 (a postmark of October 4 will not suffice). Please note that CMS will not accept comments by fax.
2) It is strongly recommended that instead of mailing comments, you submit them electronically. It saves you time and expense and ensures that your comments will be on the record – right up to the comment deadline of October 4. To submit comments electronically, simply go to the CMS website and click on the specific docket link numbered CMS-4068-P. This link allows you to submit comments as a file attachment as well.
3) Please send copies of your comments to both your state's U.S. Senators and urge them to contact CMS Administrator Dr. Mark McClellan to express support for NAMI's comments on the Medicare regulations and press CMS to include strong protections in the final regulations to ensure access to medications for vulnerable beneficiaries with severe mental illnesses. It is important that CMS hear from members of Congress on how important it is that the final regulations include a "continuity of care" requirement for dual eligibles and an alternative open formulary for beneficiaries with severe mental illnesses.