Amending Medicare: Concerns About the Proposed Advance Care Planning AspectsRule

Comments on the Proposed Rule to Amend Various Aspects of Medicare re: Reimbursing Medicare Providers for Advance Care Planning Counseling Sessions Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G Hubert H. Humphrey Building 200 Independence Avenue SW Washington, DC 20201 Attn: CMS-1625-P …we respectfully submit the following comments on the Proposed Rule to amend various aspects of the Medicare program. 80 Fed. Reg. 39840 (July 10, 2015). Our comments relate specifically to the proposal to reimburse Medicare providers for Advance Care Planning counseling sessions. See id.at 39882-83. Background [We have] no objection to encouraging patients to consider treatment decisions that may have to be made in the future, in light of their personal values and medical condition, in case they become unable to communicate their wishes. On the contrary, [there is] a long and rich tradition on the parameters for such decision making, providing concepts and distinctions that have long played an important role in secular medical ethics as well. We hold that each human life, at every stage and in every condition, has innate dignity, and that acts or omissions directly intended to take an innocent life are never justified. We also recognize that the moral obligation to preserve one’s life has limits, particularly when the means offered for supporting life may be useless or impose burdens that are disproportionate to their benefits.1. Accordingly, … and other organizations have actively participated in the nationwide debate on end-of-life decision making and on the pros and cons of various “advance directives.” Many state … conferences have even provided their own advance directives that conform...