Letters/Comments

AHA letters and comments provide insight to legislators and policymakers about laws and regulations important to the healthcare field.

A model comment letter on Proposed Rule: CMS–2393–P, Medicaid Program: Medicaid Fiscal Accountability Regulation (Vol. 84, No. 222), November 18, 2019 and CMS-2393-N (Vol. 84, No. 249) December 30, 2019, and the infographic "Financial Impact Analysis: Proposed Medicaid Fiscal Accountability Rule (…
The Medicare Payment Advisory Commission (MedPAC, or the Commission) will vote this month on payment recommendations for 2021. The American Hospital Association (AHA) asks that commissioners consider the following issues that would have a significant impact on hospitals, health systems, other…
The AHA commented on the Food and Drug Administration’s draft guidance for industry and FDA staff on clinical decision support software as part of the agency’s efforts to implement Section 3060(a) of the 21st Century Cures Act.
AHA urges CMS to reconsider its recent guidance to providers requiring them to document Medicare-Medicaid “crossover” bad debt in a manner that is neither standard practice for most hospitals nor consistent with current accounting standards.
By proposing a new safe harbor for patient engagement tools and creating three new safe harbors for value-based arrangements, the Department of Health and Human Services Office of Inspector General has taken “the first steps toward much needed reform” of the federal anti-kickback statute and civil…
The AHA today urged the Centers for Medicare & Medicaid Services to extend for 60 days – until March 17 – the comment period for its Medicaid fiscal accountability proposed rule.  
The AHA today shared comments with congressional leaders as they are working to develop a framework for a “Cures 2.0,” legislative package that builds on the 21st Century Cures Act, which became law in December 2016. 
The AHA applauded “the new direction” the Centers for Medicare & Medicaid Services is taking to modify, modernize and clarify the physician self-referral law, also known as the Stark Law, to “provide space for the types of innovative arrangements among hospitals and physicians that can enhance…
AHA and its American Organization for Nursing Leadership today voiced support for the Resolving Extended Limbo for Immigrant Employees and Families Act (S. 2603), legislation that would increase the number of employment-based visas.
This is a downloadable Model Letter to Submit Comments to CMS on Proposed Rule on Stark Law that the AHA has created for your use.