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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.




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
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
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
Interim Final Rule: Hospital COVID-19 Data Reporting, Other Provisions
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
Modernizing and Clarifying the Physician Self-Referral Regulations
Revisions to Safe Harbors Under the Anti-Kickback Statute
Proposed Acquisition Cost Survey Collection
Visas: Inadmissibility on Public Charge Grounds (Department of State)
CY 2020 OPPS Proposed Rule
CY 2020 Physician Fee Schedule Proposed Rule
Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program (SNAP)
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
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
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
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
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



Contact Senior Director of Policy Erin O’Malley at or 202.585.0127.


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