6/10/25 –
CMS RFI Response
On June 10, NPPC submitted comments in response to a Centers for Medicare & Medicaid Services (CMS) Request for Information (RFI) seeking feedback for potential changes to Medicare regulations. The goal of the RFI was to collect ideas from the public on ways to reduce health care expenditures by eliminating regulatory burdens. The RFI was issued in response to the January 31, 2025 Executive Order (EO) 14192 “Unleashing Prosperity Through Deregulation”.
NPPC’s response to the RFI, submitted on June 10th, was consistent with other organizations in the Food Is Medicine space by emphasizing opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries, Medicare Advantage and Part D plans that seek to offer Produce Prescriptions more broadly than is happening today. Responses emphasized the need for guidance that produce prescription interventions should be considered “primarily health related” supplemental benefits across all MA plans, allow specific nutrition support interventions to preemptively meet the criteria required for inclusion in the Special Supplemental Benefits for the Chronically Ill (SSBCI) plans (bibliography requirement), and lastly, issue guidance to clarify that plans are permitted to include nutrition interventions such as produce prescriptions, in the numerator of the MLR to encourage plans to more broadly make this offering available to MA beneficiaries.
