NHC Submits Comments on CMS Draft Guidance for IPAY 2028
Putting Patients First Blog
JUNE 26, 2025
7 CMS should proactively identify high-risk access scenarios—such as high-cost therapies with limited provider margins or geographic areas with fewer providers—and implement safeguards including ombudsperson support, real-time appeals processes, and monitoring of site- of-care utilization trends.
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