Legal Resources:

Letters, Testimony, Position Papers

Comment Letter
To IRS re: Revised Schedule H and Instructions, April 20, 2011
AHA, HFMA, VHA Inc., and signed state and metropolitan hospital associations submit comments on the newly revised Schedule H and Instructions.

Comment Letter
To IRS re: excise tax on medical devices, March 28, 2011
Federation of American Hospitals, the American Hospital Association, the Catholic Health Association of the United States, and the Health Industry Group Purchasing Association submit comments urging the IRS to prohibit device manufacturers from passing through the excise tax on medical devices to their customers, including hospitals.

Comment Letter
To CMS re: exception to incentive payment and shared savings program,  February 17, 2009
AHA joins AAMC and FAH in a letter to CMS in response to their additional opportunity to comment on the proposed exception to the physician self-referral law for incentive payment and shared-savings programs.

To OIG re: Special Advisory bulletin on Gainsharing Arrangements, February 17, 2009
AHA joins AAMC and FAH in a letter to OIG requesting that the 1990 OIG Special Advisory bulleting concerning “Gainsharing Arrangements and Civil Monetary Penalties for Hospital Payment to Physicians to Reduce or Limit Services to Beneficiaries” be formally withdrawn.

To CMS re: CMS' proposed exception to self-referral prohibition, August 27, 2008

To the OIG re: hospital billings/collection, Nov. 14, 2003

FTC/DOJ Health Care Hearings "Perspectives on Competition Policy and the Health Care Marketplace: Single Specialty Hospitals," March 27, 2003

FTC/DOJ Health Care Hearings "Perspectives on Competition Policy and the Health Care Marketplace," February 27, 2003

To the OIG re: credentialing practices under the anti-kickback statute, February 5, 2003

To the OIG re: the compliance program guidance for hospitals, August 19, 2002

AHA Position
The Wrongful Denial of Medicare Losses on Sale Involving Mergers and Consolidations of Non-profit Hospitals by the Department of Health and Human Services, April 2002

AHA White Paper
AHA Position on HHS' Denial of Medicare Losses in Non-Profit M&As, September 6, 2001

Special Report
To the American Hospital Association, Pneumonia Coding Project: Investigations, Defenses And Affirmative Compliance Measures, February 2001

To the OIG re: proposed safe harbor for ambulance restocking, July 21, 2000

To OIG re: Medicare and State Health Care Programs: Fraud and Abuse; Issuance of Advisory Opinion by OIG (62 Fed. Reg. 7350 et seq., February 19, 1997), April 21, 1997

To HHS Inspector General re: Solicitation of New Safe Harbors and Modifications to Existing Safe Harbors, March 3, 1997

To the IRS re: excise taxes and charitable organizations, December 12, 1996

To NAIC re: NAIC White Paper, "The Regulation of Risk-Bearing Entities," November 1, 1996

Statement of the AHA submitted to the FTC [antitrust], December 11, 1995

Special Report
"Regulation of Health Plan Companies and Provider Sponsored Networks: Practical and Public Policy Considerations", April 25, 1995



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