Centers for Medicare & Medicaid Services’ (CMS’) Request for Information: Reducing Administrative Burden to Put Patients over Paperwork


The National Health Council (NHC) appreciates the opportunity to respond to the Centers for Medicare & Medicaid Services’ (CMS’) Request for Information entitled “Reducing Administrative Burden to Put Patients over Paperwork.”

Founded in 1920, the NHC brings diverse organizations together to forge consensus and drive patient-centered health policy. The NHC provides a united voice for the more than 160 million people with chronic diseases and disabilities and their family caregivers. Made up of more than 125 diverse national health-related organizations and businesses, the NHC’s core membership includes the nation’s leading patient advocacy organizations, which control its governance and policy-making process. Other members include health-related associations and nonprofit organizations including the provider, research and family caregiver communities; and businesses representing biopharmaceutical, device, diagnostic, generic, and payer organizations.

The NHC supports policy changes and refinements that reduce the burden patients and providers face in making treatment decisions and accessing care that best aligns with the patient’s health care needs and goals. Individuals with chronic diseases and disabilities and their providers face greater overall burden within the health care ecosystem than healthier individuals due to the lifelong management of their condition. With the cost of treating and managing chronic conditions being significant and increasing,[1] initiatives to reduce the overall costs of care for the Medicare program tend to focus on higher-cost items and services individuals with chronic conditions rely upon to maintain their health and quality of life. These initiatives have often been associated with new or increased hurdles and paperwork burdens that fall disproportionately on complex patients and their treating physicians, complicating continued access to care.

The NHC continues to support thoughtful reforms and policy refinements that promote efficiency, reduce paperwork burden, contain costs, and drive higher-quality care for all Americans. Our comments focus on reducing the burden individuals with chronic conditions and their providers experience in starting or continuing treatment plans that align with the patient’s health care goals.

[1] STATISTICAL BRIEF #506: Concentration of Health Expenditures and Selected Characteristics of High Spenders, U.S. Civilian Noninstitutionalized Population, 2015, Agency for Healthcare Research and Quality, Medical Expenditure Panel Survey,

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