TMA Advocacy Comment Letters

  • TMA Advocates for Texas Physicians

    Advocacy Letters  

    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.

  • 2021 Comment Letters

    Federal

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

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

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

    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)

    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 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 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)

    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)

    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)

    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 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)

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

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

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

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

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

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

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

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

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

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

    State

    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)

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

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

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

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

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

    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)

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

    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)

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

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

  • 2020 Comment Letters

    Federal

    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 UnitedHealth Group Re: Increase in Professional Liability Insurance Coverage (Dec. 4, 2020)

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

    TMA Comment Letter to HHS Re: Request for Withdrawal of the “SUNSET” Proposed Rule (Dec. 3, 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: Waive Budget Neutrality Requirements for a Year (Oct. 26, 2020)

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

    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)

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

    Comment Letter: Clarifying Eligible Medical Expenses for Tax Deduction Purposes (Aug. 10, 2020)

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

    State

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

  • 2019 Comment Letters

    Federal

    TMA Comment Letter to the OIG Re: Anti Kickback Statute (Dec. 31, 2019)

    TMA Comment Letter to CMS Re: Stark Law (Dec. 31, 2019)

    TMA Comment Letter on 2020 Medicare Physician Fee Schedule (MPFS) and MACRA Quality Payment Program (QPP) Proposed Rule (Sept. 27, 2019)

    TMA Comments to CMS on Secure Electronic Prior Authorization for Medicare Part D (Aug. 16, 2019)

    TMA Comments to ONC on TEFCA Draft Two (June 17, 2019)

    TMA Comments to ONC on Information Blocking (June 3, 2019)

    TMA Comments to CMS on Interoperability and Patient Access (June 3, 2019)

    TMA Comments to ONC Re: Reducing Regulatory and Administrative Burden with EHRs (Jan. 28, 2019)

    State

    Comment Letter: Don't Cut Critical Vaccines' Reimbursement Rates (Feb. 11, 2019)

  • 2018 Comment Letters

    Federal

    TMA Comments to ONC Re: EHR Reporting Program Request for Information (Oct. 17, 2018)

    TMA Comments on 2019 Medicare Physician Fee Schedule and QPP Proposed Rule (Sept. 10, 2018)

    TMA Comments on Hospital Inpatient Prospective Payment Systems Rule (June 25, 2018)

    TMA Comments to ONC Regarding Draft Trusted Exchange Framework (Feb. 20, 2018)

  • 2017 Comment Letters

    Federal

    TMA Letter to CMS Re: Proposed Rules On the Medicare and Medicaid Incentive Programs that are Part of the Hospital Inpatient and Long-Term Care Hospital Prospective Payment Systems (June 13, 2017)

    TMA, AMA Letter: Defer Implementation of the 2015 Edition of Certified Electronic Health Record Technology (CEHRT) (Feb. 27, 2017)

    TMA Letter to House Chair, Kevin Brady Re: Health Information Exchange (Feb. 15, 2017)

  •  

    TMA is helping to strengthen your practice by offering advice and creating a climate of medical success across the state. 

  • What could a TMA membership mean for you, your practice, and your patients?