For regular mail or electronic submission:
Centers for Medicare and Medicaid Services
Department of Health and Human Services
PO Box 8013
Baltimore, MD 21244-1850
Dear CMS Administrator Tavenner:
Paragraph One. Clarify that you are writing about the proposal by CMS to modify the existing regulation §411.15(d)(1) to specify that the hearing aid exclusion encompasses all types of air conduction and bone conduction hearing aids (external, internal, or implanted including osseointegrated devices that CMS states function like hearing aids. We suggest that you not refer to this device as a “bone anchored hearing aid” as it is important to distinguish between prosthetic devices and hearing aids. Baha and Ponto are brand names and it is best not to reference a specific brand but rather focus on the prosthetic device generically.
Paragraph Two. Brief paragraph on who you represent (individual, clinic, or other organization) and why you are knowledgeable about the issues you will be discussing. For example, say that you are an ENT surgeon who performs the surgery or an audiologist who evaluates prior to surgery and then conducts the follow up mapping and assessment. The point is to provide credibility for your knowledge on the topic. Note that you work with Medicare age patients, if you do. If you are a parent or consumer, indicate that and personalize your letter accordingly.
Paragraph Three and Four. Discuss why you care about access to auditory osseointegrated implants and other prosthetic devices that are not hearing aids and provide important access to sound. If you can, comment on the specific benefits that you have observed by Medicare beneficiaries. Mention how the hearing provided via these prosthetic devices contributes importantly to an older person’s ability to carry out the activities of daily living. Provide examples. Note that your patients have no other option to hear other than these implanted devices as they are not helped by hearing aids. Use the attached Key Messages/Facts on Osseointegraeted Devices to help you include a few important facts here. You do not to include everything in the fact sheet; rather select one or two items that you feel comfortable discussing.
Thank CMS for its attention to your comments and your hope that the agency will re-evaluate its proposal given the significant impact it will have on this population of people who have no other option to hear other than these prosthetic devices.
Title/Affiliation (if any)