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October 10, 2013

Theresa A. Hart, RNC, MS Perinatal and Special Needs Nurse Consultant Office of the Chief Medical Officer 700 Arlington Boulevard, Suite 5101 Falls Church, VA 22042-5101

Dear Ms. Hart: The National Military Family Association has long been an advocate for improving the quality of life of our military family members who have sacrificed greatly in support of our Nation. Among our highest priorities is ensuring the children of service members receive the quality health care they need and deserve. Section 735 of the NDAA, also known as “TRICARE for Kids,” directs the Secretary of Defense to conduct a comprehensive review of TRICARE policies with respect to pediatric care. As the Department of Defense considers modifications to the TRICARE program, the National Military Family Association urges the TRICARE for Kids working group to take the following points into consideration: 

Children’s health care needs differ from those of adults. TRICARE’s policies should address the unique needs of children when defining medical necessity to ensure that military children receive comprehensive and quality health care consistent with pediatric best practices.

Because children grow and develop quickly, timely access to appropriate treatment is critical. While we recognize that access to pediatric specialty care is often hindered due to physician shortages, the situation is exacerbated by TRICARE policies that discourage provider participation in the plan. TRICARE should simplify enrollment, improve provider support, align reimbursement rates with market value, and improve payment times to facilitate a robust provider network.


Frequent moves magnify delays in accessing specialty pediatric care for military kids. Families must find new providers at each location and often experience waitlists for initial appointments resulting in gaps in care. TRICARE’s referral and approval process can add to this problem. TRICARE should eliminate policy barriers to ensure referral and authorization policies that provide for timely access to care, meet the needs of beneficiaries, and align with best practices.


Many children, including those with chronic disabilities and allergies to commercial additives, require highly customized medications. There are many instances when compound medications are the only safe and effective options for children. For this reason, TRICARE should consider the distinctive needs of children when evaluating compound pharmaceutical coverage policies.

The unique challenges faced by military families must be taken into consideration when developing TRICARE policy. It is imperative that the quality of health care provided to our military children is commensurate with the sacrifices made by our service members and their families. Thank you for the opportunity to submit comments to the TRICARE for Kids working group. If you have any questions, please contact Karen Ruedisueli, Government Relations Deputy Director, at (703)931-6632 or


Mary T. Scott Chairman, Board of Governors

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