CMS-10204 Public Comment

AARP
November 21,2006
Centers for Medicare and Medicaid Services
Office of Strategic Operations and Regulatory Affairs
Division of Regulations Development-C
Attention: Bonnie L. Harkless
Room C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

Re:

Information Collection Request - Evaluation of the Medical Adult
Day-Care Services Demonstration, Phase I

Dear Ms. Harkless:
AARP appreciates the opportunity to comment on the information collection
request for the evaluation of the medical adult day care services demonstration.
AARP believes this evaluation should provide useful information to the Centers
for Medicare and Medicaid Services (CMS) to help determine the benefits and
costs of delivering home health services in the adult day care setting.
As a protection for both the Medicare beneficiary and CMS, and to convey the
legitimacy of the survey, we recommend that beneficiaries provide written
consent to the in-home interviews in this evaluation. Written consent could be
provided prior to or at the time of the interview. While the current methodology
calls for potential interviewees to receive a letter from CMS and a call from the
researcher prior to the in-person in-home interview, only verbal consent is
provided by the beneficiary. AARP believes that written informed consent should
be included as a component of the evaluation of this demonstration program.
It is also important that CMS not ask Medicare beneficiaries to provide
unnecessary personal or financial information, such as their Social Security
number. Due in part to extensive anti-fraud efforts by AARP and others, if our
members are asked for such information in a letter or on the phone, they are
likely to throw away the letter or not respond. People may hesitate to open the
door into their private lives for legitimate survey work or research if they are
concerned about possible fraud. The more aboveboard a letter or call appears,
the more likely the consumer is to share requested information. We do note that
the letter to Medicare beneficiaries about the interview will come from the CMS
Privacy Officer on CMS letterhead. This is an improvement over the letter
coning directly from the researcher. Steps such as this benefit both Medicare
beneficiaries and CMS.

National Office ( 601 E Street, NW ( Washington, DC 20049 ( 202-434-2277 1 toll-free 1-888-OUR-AARP (1-888-687-2277)
toll-free TTY 1-877-434-7598 ( Erik D. Olsen, President ( William D. Novelli, Chief Executive Officer 1 www.aarp.org

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Thank you for considering our comments as you finalize the information
collection for this evaluation. If you have questions, please contact Rhonda
Richards on our Federal Affairs staff at (202) 434-3770.
Sincerely,

David Certner
Legislative Counsel and Legislative Policy Director
Government Relations and Advocacy