Comment Letter Archive

America’s Essential Hospitals regularly comments on proposed and final federal rules, guidance, and other regulatory actions that affect essential hospitals and vulnerable patients. Here, find copies of our comments from the past nine years.

2025
1/15/2024	Effects of Proposed Medicare Safety-Net Index on Essential Hospitals	View

2024
12/2/2024	Sanofi’s Illegal Use of Rebates to Avoid Compliance with 340B Program Requirements	View
11/7/2024	2026 Notice of Benefit and Payment Parameters Proposed Rule	View
10/31/2024	MACPAC’S Medicaid Directed Payments Discussion	View
10/11/2024	Supporting Essential Hospitals Affected by the Closure of the Baxter International Inc.’s North Cove Plant	View
10/1/2024	Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability	View
9/16/2024	Unintended Consequences of Structural Barriers on State Directed Payments that Disproportionately Harm Essential Hospitals	View
9/9/2024	CY 2025 Physician Fee Schedule Proposed Rule	View
9/9/2024	CY 2025 OPPS Proposed Rule	View
8/28/2024	Illegal Use of Rebates to Avoid Compliance with 340B Program Requirements	View
7/2/2024	Medicare Drug Price Negotiation Program (MDPNP) Draft Guidance	View
7/2/2024	Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements Proposed Rule	View
6/10/2024	FY2025 IPPS Proposed Rule	View
1/3/2024	2025 Benefit and Payment Parameters	View

2023
12/22/2023	Information Blocking Disincentives	View
9/11/2023	CY 2024 PFS Proposed Rule	View
9/11/2023	CY 2024 OPPS Proposed Rule	View
9/5/2023	OPPS Part B Remedy for 340B Hospitals	View
7/3/2023	Ensuring Access to Medicaid Services Proposed Rule	View
7/3/2023	Medicaid and CHIP Managed Care Access, Finance, and Quality Proposed Rule	View
6/9/2023	FY2024 IPPS Proposed Rule	View
5/1/2023	Medicare Disproportionate Share Hospital (DSH) Payments	View
3/13/2023	Advancing Interoperability and Improving Prior Authorization Processes	View
1/30/2023	340B Drug Pricing Program; Administrative Dispute Resolution	View
1/30/2023	2024 Notice of Benefit and Payment Parameters Proposed Rule	View
1/26/2023	Request for Information on Creating a National Healthcare System Action Alliance to Advance Patient Safety	View
1/24/2023	Confidentiality of Substance Use Disorder Patient Records	View

2022
11/7/2022	Medicaid Eligibility and Enrollment Proposed Rule	View
11/4/2022	Promoting Efficiency and Equity Within CMS Programs	View
10/3/2022	Nondiscrimination in Health Programs and Activities	View
9/13/2022	CY2023 OPPS Proposed Rule	View
9/6/2022	CY2023 PFS Proposed Rule	View
6/17/2022	FY2023 IPPS Proposed Rule	View
5/19/2022	2022 HHS Environmental Justice Strategy and Implementation	View
5/19/2022	HHS Climate Strategic Plan Outline Comments	View
4/25/2022	Public Charge Ground of Inadmissibility Proposed Rule	View
3/9/2022	2023-2026 National Health Security Strategy	View
2/25/2022	IPPS Final Rule Part 2	View
1/27/2022	2023 HHS Notice of Benefit & Payment for Affordable Care Insurance Plans	View
1/18/2022	Visas: Ineligibility Based on Public Charge Grounds	View

2021
12/6/2021	Requirements Related to Surprise Billing: Part 2	View
11/18/2021	Deferred Action for Childhood Arrivals (DACA)	View
10/22/2021	Public Charge Ground of Inadmissibility	View
9/17/2021	CY 2022 OPPS Proposed Rule	View
9/13/2021	CY 2022 Physician Fee Schedule Proposed Rule	View
9/7/2021	Requirements Related to Surprise Billing: Part 1	View
8/20/21	Occupational Exposure to COVID-19; Emergency Temporary Standard	View
6/26/2021	FY 2022 IPPS Proposed Rule	View
5/6/2021	Proposed Modifications to the HIPAA Privacy Rule To Support, and Remove Barriers to, Coordinated Care and Individual Engagement	View
1/26/2021	Most Favored Nation Interim Final Rule	View
1/11/2021	Comment Request on Proposed Medicare Cost Report Changes	View
1/22/2021	CMS Proposed Information Collection	View

2020
11/2/2020	Interim Final Rule: Hospital COVID-19 Data Reporting, Other Provisions	View
10/26/2020	Proposed Changes to Physician J-1 Visa Period of Admission	View
10/5/2020	CY 2021 OPPS Proposed Rule	View
10/5/2020	CY 2021 Physician Fee Schedule Proposed Rule	View
7/10/2020	FY 2021 IPPS Proposed Rule	View
3/9/2020	Comments to OMB on 340B Hospital Acquisition Cost Survey	View
1/31/2020	Medicaid Fiscal Accountability Regulation	View
1/29/2020	Transparency in Coverage	View

2019
12/20/2019	Modernizing and Clarifying the Physician Self-Referral Regulations	View
12/20/2019	Revisions to Safe Harbors Under the Anti-Kickback Statute	View
11/27/2019	Proposed Acquisition Cost Survey Collection	View
11/12/2019	Visas: Inadmissibility on Public Charge Grounds (Department of State)	View
9/27/2019	CY 2020 OPPS Proposed Rule	View
9/27/2019	CY 2020 Physician Fee Schedule Proposed Rule	View
9/20/2019	Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP)	View
9/13/2019	Medicaid Access Rescission	View
8/29/2019	Promoting Telehealth for Low-Income Consumers	View
8/12/2019	Request for Information on Reducing Administrative Burden to Put Patients Over Paperwork	View
8/9/2019	Nondiscrimination in Health and Health Education Programs or Activities	View
7/9/2019	Federal Housing Assistance Verification of Eligible Status	View
6/24/2019	FY 2020 IPPS Proposed Rule	View
6/11/2019	Request for Comment on the Consumer Inflation Measures Produced by Federal Statistical Agencies	View
6/3/2019	Interoperability and Patient Access for Medicare Advantage Organizations and Others	View
6/3/2019	Interoperability, Information Blocking, and the ONC Health IT Certification Program	View
3/29/2019	Request for Public Input on Overall Hospitals Quality Star Ratings	View
2/12/2019	Request for Information on Modifying HIPAA	View
1/14/2019	Medicaid and CHIP Managed Care Proposed Rule	View

2018
12/21/2018	Medicare International Pricing Index Model	View
12/10/2018	Inadmissibility on Public Charge Grounds Proposed Rule	View
11/20/2018	340B Ceiling Price and Civil Monetary Penalty Date Change	View
11/19/2018	Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction	View
10/26/2018	Anti-Kickback Statute Request for Information	View
10/16/2018	Proposed Changes to the Medicare Shared Savings Program and Accountable Care Organizations	View
9/24/2018	CY 2019 OPPS Proposed Rule	View
9/10/2018	CY 2019 Physician Fee Schedule Proposed Rule	View
8/24/2018	Request for Information Regarding the Physician Self-Referral Law	View
6/25/2018	FY 2019 IPPS Proposed Rule	View
5/22/2018	Medicaid Access Exemptions for States with High Managed Care Penetration	View
5/22/2018	340B Ceiling Price and Civil Monetary Penalty Delay	View
4/23/2018	Short-Term, Limited-Duration Insurance	View
3/6/2018	Proposed Changes to Association Health Plans	View
2/20/2018	Medicare Shared Savings Program: Extreme and Uncontrollable Circumstances for Performance Year 2017	View

2017
12/22/2017	CY 2018 Final Updates to the Quality Payment Program	View
12/11/2017	Draft 2019 Issuers Letter	View
11/27/2017	Proposed Notice of Benefit and Payment Parameters for 2019	View
10/16/17	Cancellation of Episode Payment Models, Changes to Joint Model	View
9/27/2017	Enhancements of the Overall Hospital Quality Star Rating System	View
9/11/2017	CY 2018 OPPS Proposed Rule	View
9/11/2017	CY 2018 Physician Fee Schedule Proposed Rule	View
8/28/2017	Medicaid State Disproportionate Share Hospital Allotment Reductions	View
8/21/2017	CY 2018 Proposed Updates to the Quality Payment Program	View
6/13/2017	FY 2018 IPPS Proposed Rule	View
3/8/2017	Reconciliation Bill Letter	View
3/7/2017	Market Stabilization Proposed Rule	View

2016
12/23/2016	CY 2017 OPPS Final Rule	View
12/21/2016	Pass-Through Payment Proposed Rule	View
12/19/2016	MACRA Final Rule	View
12/12/2016	Hospital-wide Risk-Standardized Mortality Measure	View
12/1/2016	Draft 2018 Issuers Letter	View
10/6/2016	Proposed Notice of Benefit and Payment Parameters for 2018	View
10/3/2016	Advancing Care Coordination Through Episode Payment Models; Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model	View
9/14/2016	Medicaid DSH Payments — Treatment of Third-Party Payers in Calculating Uncompensated Care Costs Proposed Rule	View
9/6/2016	CY 2017 OPPS Proposed Rule	View
9/6/2016	CY 2017 Physician Fee Schedule Proposed Rule	View
9/1/2016	Medicare Outpatient Observation Notice	View
8/15/2016	Conditions of Participation: Changes to Promote Innovation, Flexibility, and Improvement in Patient Care Proposed Rule	View
6/27/2016	MACRA Proposed Rule	View
6/17/2016	FY 2017 IPPS Proposed Rule	View
5/9/2016	Part B Drug Model Proposed Rule	View
1/12/2016	Draft 2016 Letter to Issuers in the Federally Facilitated Marketplaces	View

2015
12/21/2015	Medicaid Equal Access Final Rule	View
12/21/2015	Medicaid Equal Access Request for Information	View
12/15/2015	Meaningful Use Stage 3 Final Rule	View
10/27/2015	340B Proposed Mega-Guidance	View
9/8/2015	Comprehensive Care for Joint Replacement	View
8/31/2015	CY 2016 OPPS Proposed Rule	View
8/17/2015	Overall Star Ratings	View
7/27/2015	Medicaid Managed Care	View
6/16/2015	FY 2016 IPPS Proposed Rule	View
6/8/2015	Mental Health Parity	View
5/29/2015	Meaningful Use Stage 3 Proposed Rule	View

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