/ en Mon, 11 Aug 2025 09:17:40 -0500 Fri, 08 Aug 25 14:00:27 -0500 /lettercomment/2025-08-08-aha-comment-hrsa-notice-340b-rebate-model-pilot-program <div><p>August 8, 2025</p><p>The Honorable Thomas J. Engels <br>Administrator<br>Health Resources and Services Administration<br>U.S. Department of Health and Human Services <br>5600 Fishers Lane<br>Rockville, MD 20852</p><p><em><strong>Re: Application Process for the 340B Rebate Model Pilot Program (HRSA-2025- 14998)</strong></em></p><p>Dear Administrator Engels,</p><p>We, the undersigned associations, collectively represent the more than 2,000 hospitals that participate in the 340B Drug Pricing Program. On behalf of those members, we appreciate the opportunity to provide this initial comment on the Health Resources and Services Administration’s (HRSA) notice of a 340B Rebate Model Pilot Program.</p><p>As the agency acknowledges, this pilot program marks a “fundamental[] shift [in] how the 340B Program has operated for over 30 years.” A change of this magnitude requires careful consideration by all stakeholders. To that end, the agency is seeking comments on its pilot program by September 8 and has asked drug manufacturers to submit rebate model plans by September 15. That timeline gives the agency only one week to consider any stakeholder feedback, make any necessary changes to its program, and communicate those changes to all 340B stakeholders, including the drug company applicants. With the fundamental changes a rebate model will impose on all 340B stakeholders, it is impossible for the agency to meaningfully consider, in just seven days, all the feedback it will surely receive. Moreover, drug companies have spent years developing and preparing for a rebate model, but the agency’s current timeline would give 340B hospitals far less time to prepare.</p><p><strong>We, therefore, respectfully ask the agency to extend the timeline for stakeholder comments, agency consideration, and manufacturer rebate plan submissions.</strong> Specifically, we ask the agency to allow comments until <u>September 15</u> and require manufacturer submissions by <u>October 20</u>, with any rebate model plan approvals made by <u>November 3</u>. This timeline would better allow stakeholders, including the 340B hospital field, to provide the agency with meaningful feedback, on the one hand, and would give the agency more time to consider any comments and make necessary changes to its rebate model pilot program, on the other hand.</p></div><div><p>We sincerely appreciate the agency’s consideration of our request and look forward to working with all stakeholders on protecting the 340B program and the millions of patients who benefit from it.</p></div><p>Sincerely,</p><p class="text-align-center"><strong>America’s Essential Hospitals</strong></p><p class="text-align-center"><strong>American Hospital Association</strong></p><p class="text-align-center"><strong>American Society of Health-System Pharmacists </strong></p><p class="text-align-center"><strong>Association of American Medical Colleges </strong></p><p class="text-align-center"><strong>Catholic Health Association of the United States </strong></p><p class="text-align-center"><strong>Children’s Hospital Association</strong></p><p class="text-align-center"><strong>340B Health</strong></p> Fri, 08 Aug 2025 14:00:27 -0500 Letter/Comment /lettercomment/2025-07-22-aha-letter-support-medicare-mental-health-inpatient-equity-act <div class="container"><div class="row"><div class="col-md-8"><p>July 22, 2025</p><div class="row"><div class="col-md-6"><p>The Honorable Paul Tonko<br>U.S. House of Representatives<br>2269 Rayburn House Office Building<br>Washington, DC 20515</p><p>The Honorable Lloyd Doggett<br>U.S. House of Representatives<br>2307 Rayburn House Office Building<br>Washington, DC 20515</p></div><div class="col-md-6"><p>The Honorable Bill Huizenga<br>U.S. House of Representatives<br>2232 Rayburn House Office Building<<br>Washington, DC 20515</p><p>The Honorable Brian Fitzpatrick<br>U.S. House of Representatives<br>271 Cannon House Office Building<br>Washington, DC 20515</p></div></div><p>Dear Representatives Tonko, Huizenga, Doggett and Fitzpatrick:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups — the ���������� Association (AHA) is pleased to support your legislation, the Medicare Mental Health Inpatient Equity Act.</p><p>This bill would eliminate the 190-day lifetime limit on inpatient psychiatric hospital services for Medicare patients. As we work to further integrate physical and behavioral health to better address the nation’s behavioral health needs, one major obstacle to parity remains in the Medicare program — the 190-day lifetime limit on coverage for certain inpatient psychiatric treatment. As the nation’s population ages and an increasing number of seniors and people with disabilities seek inpatient care to address their behavioral health needs, now is the time to repeal this discriminatory policy and ensure that Medicare beneficiaries can receive necessary inpatient psychiatric care.</p><p>The AHA believes physical and mental health care are inextricably linked, and everyone deserves access to high-quality behavioral health care. We know that as a country we need to prioritize resources that support behavioral health needs. These investments will not only help to stymie the wave of unmet demand for behavioral health services but also improve America’s overall health.</p><p>We are grateful for your leadership on this issue and stand ready to work with you to enact this important legislation.</p><p>Sincerely,</p><p>/s/</p><p>Lisa Kidder Hrobsky<br>Senior Vice President, Advocacy and Political Affairs</p></div><div class="col-md-4"><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2025/07/AHA-Letter-in-Support-of-the-Medicare-Mental-Health-Inpatient-Equity-Act.pdf" target="_blank" title="Click here to download the AHA Letter in Support of the Medicare Mental Health Inpatient Equity Act PDF.">Download the Letter PDF</a></div><a href="/system/files/media/file/2025/07/AHA-Letter-in-Support-of-the-Medicare-Mental-Health-Inpatient-Equity-Act.pdf" target="_blank" title="Click here to download the AHA Letter in Support of the Medicare Mental Health Inpatient Equity Act PDF."><img src="/sites/default/files/inline-images/Page-1-AHA-Letter-in-Support-of-the-Medicare-Mental-Health-Inpatient-Equity-Act.png" data-entity-uuid="467c1006-fea6-4c02-aa52-afd3910d4b3d" data-entity-type="file" alt="AHA Letter in Support of the Medicare Mental Health Inpatient Equity Act page 1." width="689" height="900"></a></div></div></div> Tue, 22 Jul 2025 13:10:06 -0500 Letter/Comment /lettercomment/2025-07-22-aha-comments-cms-rfi-hospital-price-transparency-accuracy-and-completeness <div class="container"><div class="row"><div class="col-md-8"><p>July 21, 2025</p><p>The Honorable Mehmet Oz, M.D.<br>Administrator<br>Centers for Medicare & Medicaid Services<br>7500 Security Boulevard<br>Baltimore, MD 21244-1850</p><p><em>Submitted Electronically</em></p><p><em><strong>RE: CMS Hospital Price Transparency Accuracy and Completeness Request for Information</strong></em></p><p>Dear Administrator Oz:</p><p>On behalf of the ���������� Association’s (AHA’s) nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 90 that offer health plans; our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, we thank you for the opportunity to respond to the Centers for Medicare & Medicaid Services’ (CMS’) request for information (RFI) on the accuracy and completeness of hospitals’ machine-readable files.</p><p>The AHA appreciates the agency’s focus on improving price transparency. In addition to our online question submissions, we would like to share additional context and ideas on this topic. <strong>Hospitals and health systems are dedicated to improving price transparency and look forward to working together with the Administration on this important goal.</strong> The guiding principle of price transparency policies should be providing patients with clear and accurate information to help them prepare for care. An important secondary goal should be ensuring employers have the information they need as the primary purchasers of health care through employer-sponsored insurance.</p><p>We are concerned that the ongoing focus on the machine-readable files, rather than the consumer-friendly shoppable service information, diverts attention away from the price transparency efforts that are most meaningful to patients. <strong>We encourage CMS to focus future efforts on the information that will best help patients understand and compare their expected costs prior to care.</strong> The outsized focus on machine-readable file data can distract patients from the more intuitive tools that provide individualized, and therefore most accurate, estimates based on their cost-sharing amounts, their progress toward meeting their deductible and other pertinent information such as patient demographics.</p><p>Moreover, individual policy improvements rather than a comprehensive review of the numerous and sometimes conflicting price transparency requirements at both the state and federal levels are not in the best interest of patients or employers. <strong>We urge CMS to focus future efforts to reform price transparency on streamlining policies to remove complexity and administrative burden.</strong> The current landscape of pricing information is challenging for patients and employers to navigate and use effectively, and it adds excessive costs, confusion and workforce burden to the health care system.<a href="#fn1"><sup>1</sup></a><sup>,</sup><a href="#fn2"><sup>2</sup></a><sup>,</sup><a href="#fn3"><sup>3</sup></a> Addressing the hospital machine-readable files in isolation is misguided; CMS should coordinate and streamline any future changes across all hospital and insurer requirements to create a price transparency environment that is both usable and meaningful to patients and employers.</p><p>Please see below our specific comments and recommendations on the issues identified in the RFI.</p><h2>Accuracy and Completeness of the Machine-Readable File Data</h2><p><strong>Determining the accuracy and completeness of machine-readable file data is inherently challenging given that exact rates do not exist in the way envisioned by this policy.</strong> This is because the data required in the machine-readable files, specifically the estimated allowed amount data, does not exist outside of what hospitals and insurers create to input into the files. In other words, because the files require hospitals to break down services in a manner that is not common for how rates are negotiated or stored in hospital or insurer internal systems, hospitals effectively must create new rates specific for this purpose. While they do their best to create negotiated rates that are as close as possible to how the final services may ultimately be paid, hospitals must make detailed assumptions about how to apply complex contracting terms and assess historic data to create a reasonable value for an expected allowed amount.</p><p>For example, to develop the negotiated rate for a colonoscopy, hospitals can use historic claims data to calculate the average price the insurer paid for the service previously, recognizing that variation exists due to differences in patient acuity and the care process (e.g., the amount of anesthesia required), as well as the potential for additional procedures that may be performed during the screening. These may include diagnostic interventions such as biopsies, polyp removal or lesion cauterization, each of which introduces additional clinical complexity, supply use, staff time and billing variation that can significantly affect the total allowed amount for the encounter. Hospitals may also apply additional expected contracting terms to that estimate (e.g., how modifiers or stop-loss provisions may impact the final payment amount) that introduce additional complexity to the calculation. This is even more complicated in instances where there is not sufficient, or any, historic data available on which to reasonably base the calculations. Ultimately, there is no tool or dataset that CMS could use to assess or verify these calculations, and <strong>we continue to strongly support attestations of accuracy for purposes of CMS assessments.</strong></p><p>In addition, the machine-readable data is, at best, a historic representation of the likely payment amount for an item or service. It cannot be carried over to individual cases as the price for a specific patient’s service will always require consideration of the unique factors of that case. For example, the negotiated rate for the colonoscopy discussed above likely would be lower than expected for a high acuity patient and higher than expected for a low acuity patient. Moreover, that amount does not reflect the patients’ cost-sharing amount, but rather the total amount inclusive of both the insurer and patient responsibilities. Finally, even if the information was relevant to the patient, the machine-readable files are hard to navigate. For example, there likely would be multiple colonoscopy lines reflecting different types of procedures (e.g., preventive versus diagnostic) and patients would need to have high health care literacy to determine the correct line item. Moreover, none of this information accounts for how the cost for the patient would change if a preventive colonoscopy became a diagnostic colonoscopy mid-service, given how health insurance treats these instances differently.</p><p><strong>Fortunately, there are tools that already exist to provide individualized estimates to patients as part of both the hospital and insurer shoppable service requirements.</strong> In addition, once the No Surprises Act is fully in effect, all patients will receive good faith estimates or advanced explanations of benefits prior to scheduled care, as the act requires. While these are by definition “estimates,” they are much more likely to produce usable and reliable cost expectations than the machine-readable files because they are based on an individual’s specific situation.</p><p>As an alternative, CMS could focus its efforts on ensuring that pre-service estimates are as accurate as possible. One way to do this would be to change benefit design requirements to reduce or eliminate cost-sharing that is calculated after the course of care is complete and instead rely solely on flat co-payments. That way, even if the total price varies as discussed above, the patient portion remains the same. Another alternative could be to remove providers from the cost-sharing collection process altogether and instead require insurers to be responsible for cost-sharing estimates and collections. This would incentivize more predictable and transparent benefit design as insurers would likely create more rational benefit packages if they were at risk for patient non-payment as providers are today.</p><h2>Enforcement</h2><p>Since the hospital price transparency requirements took effect in 2021, CMS has changed the requirements and guidance several times. While many of these changes have made expectations clearer and easier to comply with, their repeated implementation requires significant time and resources. Also, since 2021, CMS has steadily increased its enforcement efforts.<a href="#fn4"><sup>4</sup></a> Between Jan. 7, 2021, and March 31, 2025, CMS engaged in over 6,000 audits and enforcement actions related to hospital price transparency compliance as part of over 3,000 unique cases. Of these more than 3,000 cases, almost 1,000 were found to comply at the time of the audit and another nearly 2,000 came into compliance following CMS action. Most of the roughly 300 remaining cases were opened in 2025 and the hospitals in question are now actively working to come into compliance. It is because of hospitals’ efforts that CMS has only issued 27 civil monetary penalties, rather than a lack of CMS’ active auditing or enforcement.</p><p>As a result of a steep learning curve, many of the initial issues CMS identified required weeks, or sometimes months, for hospitals to resolve. The issues identified now are typically minor, and AHA has heard from hospitals that cases are often opened and closed within hours. We understand that the relationship between CMS and hospitals throughout this process has been positive and collaborative and we appreciate CMS’ willingness to work with hospitals to achieve compliance.</p><p><strong>Given the prolific auditing and enforcement already occurring, additional enforcement of the hospital price transparency requirements is not necessary.</strong> However, there are steps that CMS could take that would help streamline the auditing and compliance process. To begin, we recommend that CMS notify hospitals following a positive audit to let them know that they have been found to be in compliance with the requirements. It appears that CMS tracks this based on the publicly available enforcement data, but hospitals are not currently receiving this information directly from CMS. In addition, we have heard from many hospitals that more clarity in CMS’ initial warning notices would be helpful. In many instances, delays in responding to compliance concerns are due to confusion around what issue CMS is identifying. If CMS could provide more detail about what specific issues they found during their audits, hospitals would be able to more promptly address them.</p><p>Finally, we encourage CMS to direct additional auditing and enforcement resources to the Transparency in Coverage requirements. As discussed previously, the insurer data holds great potential to advance CMS’ price transparency objectives and allow for better streamlining but these benefits will not be realized until the data is more usable and reliable.</p><p>Thank you for your consideration, and we look forward to working with the Administration to improve price transparency for patients. Please contact me if you have questions or feel free to have a member of your team contact Ariel Levin, AHA’s director of coverage policy, at <a href="tel:1-202-626-2335">202-626-2335</a> or <a href="mailto:mailto:alevin@aha.org?subject=RE: AHA Comments on CMS RFI on Hospital Price Transparency Accuracy and Completeness">alevin@aha.org</a>.</p><p>Sincerely,</p><p>/s/</p><p>Ashley Thompson<br>Senior Vice President, Public Policy Analysis and Development</p><hr><ol><li id="fn1"><a href="/fact-sheets/2023-02-24-fact-sheet-hospital-price-transparency" target="_blank">/fact-sheets/2023-02-24-fact-sheet-hospital-price-transparency</a></li><li id="fn2"><a href="/system/files/media/file/2023/09/aha-comments-on-cms-outpatient-and-ambulatory-surgery-prospective-payment-system-proposed-rule-for-cy-2024-letter-9-8-23.pdf" target="_blank">/system/files/media/file/2023/09/aha-comments-on-cms-outpatient-and-ambulatory-surgery-prospective-payment-system-proposed-rule-for-cy-2024-letter-9-8-23.pdf</a></li><li id="fn3"><a href="/system/files/media/file/2021/03/aha-comments-on-no-surprises-act-price-transparency-provisions-letter-3-16-21.pdf" target="_blank">/system/files/media/file/2021/03/aha-comments-on-no-surprises-act-price-transparency-provisions-letter-3-16-21.pdf</a></li><li id="fn4"><a href="https://data.cms.gov/provider-characteristics/hospitals-and-other-facilities/hospital-price-transparency-enforcement-activities-and-outcomes" target="_blank">https://data.cms.gov/provider-characteristics/hospitals-and-other-facilities/hospital-price-transparency-enforcement-activities-and-outcomes</a></li></ol></div><div class="col-md-4"><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2025/07/AHA-Comments-on-CMS-RFI-on-Hospital-Price-Transparency-Accuracy-and-Completeness.pdf" target="_blank">Download the Letter PDF</a></div><a href="/system/files/media/file/2025/07/AHA-Comments-on-CMS-RFI-on-Hospital-Price-Transparency-Accuracy-and-Completeness.pdf" target="_blank"><img src="/sites/default/files/inline-images/Page-1-AHA-Comments-on-CMS-RFI-on-Hospital-Price-Transparency-Accuracy-and-Completeness.png" data-entity-uuid="c9143e7c-0d65-4942-a67e-aac5c82b19e5" data-entity-type="file" alt="AHA Comments on CMS RFI on Hospital Price Transparency Accuracy and Completeness page 1." width="695" height="900"></a></div></div></div> Tue, 22 Jul 2025 06:00:00 -0500 Letter/Comment /lettercomment/2025-07-16-aha-expresses-support-protect-medicaid-and-rural-hospitals-act <p>July 16, 2025 </p><p>The Honorable Josh Hawley<br>United States Senate<br>115 Russell Senate Office Building<br>Washington, DC 20510 </p><p>Dear Senator Hawley: </p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) writes to express our appreciation for your leadership during the debate on the reconciliation package and offer support for your legislation, the Protect Medicaid and Rural Hospitals Act. If enacted, your legislation will help hospitals and communities mitigate the impact of the Medicaid reductions that were part of the recently enacted One Big Beautiful Bill Act (OBBBA; Public Law No: 119-21). </p><p>The Medicaid program provides services for 72 million Americans, and the OBBBA would reduce federal support for the program by nearly $1 trillion and cause many millions of people to lose access to health insurance. Among the law’s provisions are significant changes to how provider taxes and state directed payments (SDPs) will operate. Provider taxes and SDPs are important tools states use to ensure providers are more adequately reimbursed by a program that historically underpays them for the care they deliver to Medicaid patients. In 2023, Medicaid underpaid hospitals and health systems nationwide by $27.5 billion for treating program beneficiaries. SDPs also support hospital financial viability and allow them to offer essential services for Medicaid recipients, including labor and delivery and behavioral health care, which ultimately contributes to the wellbeing of everyone served by their local facility. The Congressional Budget Office estimates Sections 71115 and 71116 of the OBBBA would cut $340 billion in federal funding from the Medicaid program over the next 10 years. Your legislation strikes these two sections to mitigate the impact of Medicaid reductions on hospitals and health systems and allow them to continue to serve their patients and communities. </p><p>In addition, you build upon the provisions of the OBBBA that seek to assist rural hospitals, some of which are struggling to operate, even before the major policy changes of the OBBBA are enacted. The Protect Medicaid and Rural Hospitals Act provides for an additional $50 billion for the Rural Health Transformation program. These funds are a positive step toward mitigating some of the other Medicaid policy changes in the OBBBA that could negatively impact rural hospitals. </p><p>Thank you for your continued attention to the issues that affect America’s hospitals and health systems, and we look forward to working with you to increase support for your legislation. </p><p>Sincerely, </p><p>/s/ </p><p>Richard J. Pollack<br>President and Chief Executive Officer   </p> Wed, 16 Jul 2025 14:21:17 -0500 Letter/Comment /lettercomment/2025-07-14-aha-comments-hhs-rfi-maha-initiative <p>July 14, 2025</p><p>Laina Bush<br>Acting Assistant Secretary for Planning and Evaluation<br>U.S. Department of Health and Human Services <br>200 Independence Avenue, S.W.<br>Washington, DC 20201</p><p>Jennifer Burnszynski<br>Associate Deputy Assistant Secretary, Office of Human Services Policy<br>U.S. Department of Health and Human Services <br>200 Independence Avenue, S.W.<br>Washington, DC 20201</p><p><em>Submitted Electronically</em></p><p><em><strong>RE: AHRQ 2025-001 Request for Information; Ensuring Lawful Regulation and Unleashing Innovation to Make America Healthy Again</strong></em></p><p>Dear Ms. Bush and Ms. Burnszynski,</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) appreciates the opportunity to provide comments on the request for information (RFI) to ensure lawful regulation and unleash innovation to promote better health.</p><p>The AHA agrees that reducing unnecessary administrative burden can foster improved health for the American people. The rescission of certain regulations will not only support reduced health care costs but also will increase access and quality of care as providers can focus more on direct patient care and less on burdensome paperwork. </p><p>This is essential to address, as more than a quarter of all health care spending goes to administrative tasks — totaling more than $1 trillion annually.<sup>1</sup></p><p>As the AHA shared in recent responses to RFIs on deregulation from the <a href="/system/files/media/file/2025/05/aha-response-to-omb-deregulation-rfi-letter-5-12-2025.pdf">Office of Management and Budget</a>, <a href="/system/files/media/file/2025/05/AHA-Comments-on-FTC-Anticompetitive-Deregulations-RFI.pdf">Federal Trade Commission</a> and <a href="/system/files/media/file/2025/05/AHA-Comments-on-DOJ-Anticompetitive-Deregulations-RFI.pdf">Department of Justice</a>, there are a variety of actions the administration could take to reduce the burden on hospitals and health systems to improve access, reduce costs and foster competition.<sup>2,3,4</sup> Many of our recommendations included in those responses are relevant to the questions posed in this RFI and can be accessed by the hyperlinks above. In addition, we shared a more comprehensive list of 100 ways to free hospitals from burdensome administrative requirements, an updated version of which is attached. Given our prior responses, we focus these comments on the issue in this RFI that we have not previously addressed directly: regulatory changes to help reverse chronic disease.</p><p>We applaud the administration’s focus on reducing chronic disease, particularly among children. Compared to other developed countries, the U.S. has higher rates of chronic disease and the lowest life expectancy.<sup>5,6</sup>  The rate of premature death in the U.S. is twice that of other developed nations, mainly driven by cardiovascular disease, chronic respiratory illness and chronic kidney disease.<sup>7</sup> The growing prevalence of chronic disease in America has contributed to increased utilization of hospital services and higher case-mix indices, which contribute to higher health care costs.</p><p>There are clear areas of alignment between the administration’s interest in addressing chronic disease and hospitals’ work. Hospitals are a primary source of diagnosis and treatment for individuals with chronic illnesses. Many hospitals also are “moving upstream” and helping to address the root causes of chronic illness before they take hold. Some examples of hospitals’ work in this space include:</p><ul><li><strong>Prioritizing food and nutrition.</strong> Three out of four hospitals offer nutrition programs to help their community build healthier lives by tackling food and diet-related health challenges. Also, many hospitals have developed “Food Is Medicine” programs, or food prescription programs, to provide fresh fruits and vegetables for patients experiencing food insecurity or to treat chronic conditions.</li><li><strong>Preventing and managing chronic illnesses.</strong> Most hospitals offer free health screenings, giving patients the opportunity to catch health issues early and prevent the development of complex or long-term conditions when possible.</li><li><strong>Promoting wellness.</strong> Hospitals provide health education and other tools to help people make healthy lifestyle choices to reduce risk for conditions such as stroke, diabetes, heart disease, certain cancers and depression.</li></ul><p>The AHA has compiled a <a href="/system/files/media/file/2025/05/2025-AHA-MAHA-Report.pdf">report</a> and list of programs across all 50 states to demonstrate the critical work hospitals do every day to combat chronic illness. There are countless other examples, including hospitals offering transportation programs to help patients get to and from appointments, partnering to build safe housing options, and providing community resources to reduce isolation.</p><p>The AHA recently met with several hundred hospital leaders to discuss further efforts to address chronic disease in America. Several key themes emerged:</p><ul><li>Addressing both the causes and the treatment of chronic disease must be done in partnership with community organizations, especially in rural and underserved areas. No single organization has the expertise, resources or capacity to comprehensively address chronic disease alone.</li><li>Chronic disease is not limited to physical ailments. Behavioral and mental health conditions also can be chronic diseases and are frequent co-morbidities alongside physical illness.</li><li>In addition to addressing environmental and systemic issues contributing to chronic disease, patients must also adopt healthy behaviors.</li><li>Hospitals are not reimbursed for interventions that are not directly related to the services they provide. Hospitals and health systems will have limited capacity to take on additional responsibilities without financial support.</li><li>Health care coverage is critical to ensuring access to the care needed to help diagnose, treat and manage chronic diseases.    </li></ul><p><strong>Recommendations</strong></p><p>The AHA offers the following initial recommendations on deregulation opportunities to address chronic disease in the context of this RFI. We look forward to an ongoing dialogue with the administration about how hospitals can support our shared objective of reducing the incidence and burden of chronic disease in this country.</p><p><strong>Reduce administrative and coverage barriers to care. </strong>Patients often face difficulties accessing health care services due to coverage-related issues. For example, health plans’ prior authorization requests reached nearly 50 million in 2023 for Medicare Advantage beneficiaries alone, an increase from 42 million in 2022.<sup>8</sup> Uncertainty about costs — most often a function of understanding health plan cost-sharing obligations — can also create a barrier to care. To help patients access the care they need to prevent, diagnose and manage chronic illness, we encourage the Administration to:</p><ul><li>Fully operationalize the Interoperability and Prior Authorization Final Rule to establish standard electronic prior authorization processes in Medicare Advantage, the Health Insurance Marketplaces and Medicaid. This will help expedite patients’ access to medically necessary services.</li><li>Support patients in accessing pricing information by streamlining the various provider and insurer price transparency requirements and eliminating redundancies in reporting. Reducing complexity could help patients better understand their health care costs, potentially reducing a barrier to accessing care.</li></ul><p><strong>Advance the sustainable adoption of technology and innovation.</strong> Telehealth and other technologies show considerable promise in helping individuals manage their health, including chronic illness. However, as technology and consumer preferences have evolved, many regulations have not kept pace with innovation, potentially impeding patients’ access to services that could help them manage their chronic conditions. The AHA encourages the Administration (and Congress where appropriate) to:</p><ul><li>Remove telehealth originating site restrictions within the Medicare program to enable patients to receive telehealth in their homes.</li><li>Remove telehealth geographic site restrictions to enable beneficiaries in non-rural areas to have the same access to virtual care as those in rural areas.</li><li>Remove the in-person visit requirements for behavioral health telehealth.</li><li>Eliminate the telehealth physician home address reporting requirement, which compromises workforce safety.</li></ul><p><strong>Facilitate whole-person care. </strong>Chronic disease is rarely caused by a single factor, nor is it successfully treated in isolation. There are several ways in which existing regulations stymie providers’ ability to provide whole-person care. To address these issues, we encourage the administration to:</p><ul><li>Eliminate 42 CFR Part 2 requirements that protect patient privacy under HIPAA but hinder care team access to important health information, specifically, separation of records pertaining to substance use disorder information. As previously stated, there is a strong link between physical and behavioral health, especially with respect to chronic disease. In order to provide the best care possible, providers must have access to their patients’ full medical records.</li><li>Modernize the Stark Law and Anti-Kickback Statute regulations to better protect arrangements that promote value-based care. Whole-person care also entails care coordination and continuity, particularly for patients with chronic disease. Historically, these laws have had the effect of impeding value-based arrangements involving care coordination and/or collaborative electronic platforms by making many of them difficult to undertake without running afoul of either or both laws. Critical steps were taken by the first Trump administration to promote care coordination through value-based safe harbors under those laws, and we continue to support these safe harbors and recommend that they be maintained in their current form. To further address this challenge, we would encourage the adoption of a broad Anti-Kickback Statute safe harbor akin to the “access to care/low risk of harm” exception to the Civil Monetary Penalties Law, which would immunize arrangements that promote access to health care items or services and present a low risk of harm to patients and federal health care programs. This would more effectively protect (and therefore promote) beneficial arrangements that clearly improve patient access to health care items or services. </li></ul><p><strong>Sustain the health care workforce.</strong> The health care system relies on doctors, nurses and other clinicians to diagnose, treat and manage chronic disease. Unfortunately, our health care workforce is increasingly burning out and leaving the profession, often citing excessive administrative burdens that pull them away from patient care. This can lead to delays in patients accessing the care they need to manage their chronic conditions. In order to support the workforce, the AHA encourages the Administration to:</p><ul><li>Streamline care plan documentation requirements to eliminate<strong> </strong>duplicate paperwork by removing the requirement for distinct nursing care plans when an interdisciplinary team is caring for the patient and maintains an interdisciplinary care plan.</li><li>Support expanding care capacity by removing Medicare restrictions on nurse practitioners and other advanced practice providers that are often more restrictive than under state licensure.</li><li>Permanently remove the requirements for outpatient physical therapy plans of care to be signed and dated every 90 days.</li></ul><p>We look forward to opportunities to work with the administration on these and further recommendations to reduce unnecessary, unfounded or redundant regulations with a particular focus on how we can support individuals to live their healthiest lives. Please contact me if you have questions, or feel free to have a member of your team contact Jennifer Holloman, AHA’s director of policy, at <a href="mailto:jholloman@aha.org" title="Email address">jholloman@aha.org</a>.</p><p>Sincerely,</p><p>/s/</p><p>Ashley Thompson<br>Senior Vice President<br>Public Policy Analysis and Development</p><div><hr><div id="ftn1"><p><small class="sm"><sup>1</sup> “Active steps to reduce administrative spending associated with financial transactions in US health care,” Sahni, N., et. al., Health Affairs Scholar, Volume 1, Issue 5, November 2023, qxad053, </small><a href="https://doi.org/10.1093/haschl/qxad053"><small class="sm">https://doi.org/10.1093/haschl/qxad053</small></a><small class="sm">.</small></p></div><div id="ftn2"><p><small class="sm"><sup>2</sup></small><a href="/system/files/media/file/2025/05/aha-response-to-omb-deregulation-rfi-letter-5-12-2025.pdf"><small class="sm">/system/files/media/file/2025/05/aha-response-to-omb-deregulation-rfi-letter-5-12-2025.pdf</small></a><small class="sm">.</small></p></div><div id="ftn3"><p><small class="sm"> <sup>3</sup></small><a href="/system/files/media/file/2025/05/AHA-Comments-on-FTC-Anticompetitive-Deregulations-RFI.pdf"><small class="sm">/system/files/media/file/2025/05/AHA-Comments-on-FTC-Anticompetitive-Deregulations-RFI.pdf</small></a><small class="sm">.</small></p></div><div id="ftn4"><p><small class="sm"><sup>4</sup></small><a href="/system/files/media/file/2025/05/AHA-Comments-on-DOJ-Anticompetitive-Deregulations-RFI.pdf"><small class="sm">/system/files/media/file/2025/05/AHA-Comments-on-DOJ-Anticompetitive-Deregulations-RFI.pdf</small></a><small class="sm">.</small></p></div><div id="ftn5"><p><small class="sm"><sup>5 </sup></small><a href="https://www.healthsystemtracker.org/chart-collection/how-has-the-burden-of-chronic-diseases-in-the-u-s-and-peer-nations-changed-over-time/#:~:text=Broadly%2C%20a%20larger%20share%20of,of%20depression%20(1.3%20times)"><small class="sm">https://www.healthsystemtracker.org/chart-collection/how-has-the-burden-of-chronic-diseases-in-the-u-s-and-peer-nations-changed-over-time/#:~:text=Broadly%2C%20a%20larger%20share%20of,of%20depression%20(1.3%20times)</small></a><small class="sm">.</small></p></div><div id="ftn6"><p><small class="sm"><sup>6</sup> </small><a href="https://www.healthsystemtracker.org/chart-collection/u-s-life-expectancy-compare-countries/#Life%20expectancy%20at%20birth%20by%20sex,%20in%20years,%202023"><small class="sm">https://www.healthsystemtracker.org/chart-collection/u-s-life-expectancy-compare-countries/#Life%20expectancy%20at%20birth%20by%20sex,%20in%20years,%202023</small></a><small class="sm">.</small></p></div><div id="ftn7"><p><small class="sm"><sup>7</sup> </small><a class="ck-anchor" href="https://www.healthsystemtracker.org/chart-collection/what-drives-differences-in-life-expectancy-between-the-u-s-and-comparable-countries/" id="https://www.healthsystemtracker.org/chart-collection/what-drives-differences-in-life-expectancy-between-the-u-s-and-comparable-countries/."><small class="sm">https://www.healthsystemtracker.org/chart-collection/what-drives-differences-in-life-expectancy-between-the-u-s-and-comparable-countries/</small></a><a class="ck-anchor" id="https://www.healthsystemtracker.org/chart-collection/what-drives-differences-in-life-expectancy-between-the-u-s-and-comparable-countries/."><small class="sm">.</small></a></p><div><div id="ftn1"><p><small class="sm"><sup>8</sup> </small><a href="https://www.kff.org/medicare/issue-brief/nearly-50-million-prior-authorization-requests-were-sent-to-medicare-advantage-insurers-in-2023/"><small class="sm">https://www.kff.org/medicare/issue-brief/nearly-50-million-prior-authorization-requests-were-sent-to-medicare-advantage-insurers-in-2023/</small></a><small class="sm">.</small></p><hr><h4 class="text-align-center">Attachment</h4><h4 class="text-align-center">100 Ways to Free Hospitals from Wasteful and Burdensome Administrative Requirements to Provide the Highest Quality, Most Efficient Care to Patients </h4><h2>BILLING, PAYMENT AND OTHER ADMINISTRATIVE REQUIREMENTS </h2><p>Research estimates that between 25% and 35% of all health care spending is on administrative tasks, with billing and collections, which include coverage and eligibility verification, being one of the costliest areas. The following changes could dramatically lower administrative costs; many would also improve patient access to care. </p><h3>Interactions with Health Plans</h3><ol><li>Eliminate duplicative and costly billing infrastructure within hospitals, health systems and other providers by shifting cost-sharing collection responsibilities to insurers — the entities that set co-pay, deductible and co-insurance amounts.</li><li>Reduce variation in prior authorization processes by enforcing the interoperability and prior authorization final rule, which will streamline electronic prior authorization processes across many payers.</li><li>Eliminate billions in excess health care system costs, resulting from providers chasing payment from insurers, by establishing prompt pay requirements in all forms of health care coverage, including Medicare Advantage.</li><li>Implement a standardized claims attachment to allow plans to request and providers to transmit necessary medical records via a safe electronic transmission standard.</li><li>Reduce the time providers waste tracking down the unique criteria that each Medicare Advantage plan uses to adjudicate claims by establishing a single clinical standard for both Traditional Medicare and Medicare Advantage.</li><li>Reduce the time patients spend waiting for post-acute care placements by disallowing plans from implementing prior authorization requirements for these services in certain circumstances.</li><li>Eliminate duplication and data collection burdens on providers by establishing a single national provider directory and requiring plans to exclusively use the national database rather than create their own.</li><li>Remove requirements for payers and plans to have separate credentialing processes and allow for payers to instead recognize hospital credentialing.</li><li>Adopt a standard process for providers to appeal a Medicare Advantage plan denial of a prior authorization request or claim.</li><li>Minimize the burden of managing pharmaceutical supplies while improving patient safety by prohibiting insurers from unilaterally adopting policies that force providers to use pharmaceuticals provided by the insurer’s affiliated pharmacy benefit manager rather than using their own supply (also known as “white bagging”).</li><li>Establish and enforce network adequacy requirements for post-acute care on Medicare Advantage plans to enable patients to begin necessary post-acute care as timely as possible while freeing up inpatient capacity.</li><li>Improve the flawed and cumbersome No Surprises Act Independent Dispute Resolution process while retaining the patient protections against surprise billing to allow insurers and out-of-network hospitals and health systems to work together more efficiently to determine appropriate reimbursement.</li><li>Remove the prior authorization requirement for non-emergent Veterans Affairs community care network services, which requires providers to submit a form that takes at least three days to process, therefore unnecessarily delaying care.</li><li>Expand access to alternative coverage options for employees, such as through Individual Reimbursement Arrangements, which would reduce the administrative burden on employers.</li></ol><h3>Information Technology and Coding</h3><ol start="15"><li>Repeal the excessive and confusing “information blocking” rule that would impose unjustified penalties on providers.</li><li>Modify the HIPAA cybersecurity rule of December 2024 to make the requirements voluntary.</li><li>Modify the HIPAA Breach Notification Rule to remove the requirement to report breaches affecting fewer than 500 individuals.</li><li>Eliminate billing and coding requirements for psychiatric care at 42 CFR 483.102as they are overly stringent and not based on medical criteria.</li><li>Streamline the Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) code sets to standardize reporting across all payors.</li><li>Eliminate unique HCPCS codes for generic drugs, which adds burden by complicating the billing process. </li></ol><h3>Administrative and Regulatory Barriers to Care</h3><ol start="21"><li>Repeal the Food and Drug Administration Laboratory Developed Tests final rule that will hamper hospital labs’ ability to continue developing high-quality in-vitro tests that have increased access to care and reduced costs.</li><li>Repeal the Institutions for Mental Disease exclusion within the Medicaid program so that hospitals and other providers can ensure Medicaid patients who need inpatient behavioral health care can get the most effective care efficiently.</li><li>Similarly, repeal the 180-day lifetime limit on inpatient psychiatric facility services under Medicare.</li><li>Allow inpatient rehabilitation facilities (IRFs) to care for more than just inpatient rehabilitation patients when capacity is an issue (such as during a pandemic), which could reduce patient wait times for care.</li><li>Eliminate the observation hours “carve-out” policy for diagnostic or therapeutic services.</li><li>Simplify the detailed and complex reporting process of the Medicare Cost Reports.</li><li>Modernize the Stark Law and Anti-kickback Statute regulations to better protect arrangements that promote value-based care.</li><li>Repeal the requirement that Critical Access Hospital (CAH) based ambulance services only receive cost-based reimbursement if they are the sole ambulance provider within 35 miles. Instead, all CAH-based ambulance providers should receive cost-based reimbursement.</li><li>Modify Environmental Protection Agency project building timelines that significantly delay the construction of new sites of care.</li><li>Expand hospitals’ ability to utilize swing beds.</li><li>Improve the timeliness and efficiency of 340B child site registration by re-adopting the prior policy of allowing hospitals to register child sites under the 340B program even if they are not included on their most recently filed cost report.</li></ol><h3>Medicare Payment and Processes</h3><ol start="32"><li>Repeal the IRF Review Choice Demonstration under which IRFs will have 100% of their traditional Medicare claims subject to either pre- or post-claim review for at least six months.</li><li>Repeal the Center for Medicare and Medicaid Innovation’s (CMMI) Increasing Organ Transplant Access mandatory kidney transplant model that purports to better align payment with quality but over-focuses on quantity over quality.</li><li>Make voluntary all CMMI models with particular focus on the recently announced Transforming Episode Accountability Model, which will mandate that some of the most vulnerable hospitals transition to bundled payments for five types of surgical episodes.</li><li>Eliminate the skilled nursing facility three-day length of stay requirement that often delays patients from transitioning to the most appropriate site of care.</li><li>Simplify and expedite discharge processes by removing the requirement that hospitals provide patients with a list of post-acute care (PAC) providers from which to select when hospitals already work with patients and PAC providers for appropriate placement.</li><li>Eliminate the CAH 96-hour rule as a condition of participation (CoP) which requires an annual average length of stay of 96 hours or less and eliminate the 96-hour condition of payment rule that requires physicians in CAHs to certify upon admission that an inpatient can be reasonably expected to be discharged or transferred to another hospital within 96-hours.</li><li>Eliminate the requirement that a hospital operate for at least six months under the prospective payment system before converting to CAH status.</li><li>Eliminate the “must-bill” policy for dual eligible beneficiaries, which requires providers to bill both Medicare and Medicaid even though no Medicaid payment may be expected.</li><li>Allow for exceptions to the requirement that Medicare overpayments are returned in 180 days, given that providers may need additional time to complete investigations.</li><li>Allow Medicare bad debts to be written off as contractual allowances, which is consistent with standard accounting practices and was permitted under prior policies.</li><li>Eliminate the policy that to receive Medicare bad debt reimbursement for dual eligible beneficiaries, providers must bill the state Medicaid program AND receive/submit the remittance advice listing any Medicaid payment, which is burdensome and not always possible.</li><li>Standardize coverage, coding and billing criteria among Medicare Administrative Contractors (MACs).</li><li>Remove the restriction that disallows hospitals from choosing a different MAC.</li><li>Streamline the Medicare appeals process to allow uploading of medical records at the time of claim filing.</li><li>Streamline Medicare mandatory notices to patients, including eliminating where applicable rules require providers to give notice both in-person and via paper notices. Examples of such notices include the Important Message from Medicare, Advance Beneficiary Notice of Non-coverage, and Medicare Outpatient Observation Notice, the Notice of Medicare Non-Coverage and Medicare Change of Status Notice.</li><li>Rescind Centers for Medicare and Medicaid Services (CMS) regulations requiring hospitals to report detailed information about drug invoices on their cost reports beginning in 2026. Manufacturers should be required to report the additional pricing information necessary for CMS to create average sales prices.</li><li>Revise Medicare drug price negotiation guidance to prohibit drug manufacturers from implementing retrospective rebate models in the 340B Drug Pricing Program, which would add considerable administrative costs to hospitals serving the most vulnerable communities.</li><li>Strengthen Medicare-dependent and Sole Community Hospitals by allowing participating hospitals to choose from an additional base year when calculating payments. </li></ol><h3>Price Transparency </h3><ol start="50"><li>Eliminate the convening provider requirement as part of good faith price estimates given to patients, because there is no technical solution to operationalize it.</li><li>Create a more streamlined and accurate process for patients to access pricing information by having insurers serve as the “source of truth” by publishing the negotiated rates and requiring hospitals to post cash price and chargemaster rates. </li></ol><h2>QUALITY AND PATIENT SAFETY </h2><p>High-quality, safe care is the core of hospitals’ missions. While many regulations originated out of an interest to improve care quality or patient safety, those same regulations, over time, have often become obsolete or redundant. However, in many cases, they remain required despite having outlived their usefulness. The following changes would support hospitals’ efforts to adapt to continue offering the highest quality, safest care. </p><h3>Quality Reporting </h3><ol start="52"><li>Repeal the onerous and now outdated CoP that requires hospitals to report data on acute respiratory illnesses, including influenza, COVID-19 and RSV, once per week, with more frequent and extensive data reporting required during a public health emergency.</li><li>Reduce administrative burden by eliminating the outdated requirement for post-acute care providers to report COVID-19 and influenza vaccine rates for patients/residents and staff.</li><li>Similarly, remove the outdated requirement for hospitals to report staff vaccination rates.</li><li>Remove the sepsis bundle measure, which evidence shows has not led to better outcomes but entails an enormous administrative burden, from all hospital quality reporting and value programs, replacing it with a measure of sepsis outcomes.</li><li>Eliminate (or at minimum streamline) the Meaningful Use (now Promoting Interoperability) program as it has outlived its usefulness.</li><li>Eliminate (or, at a minimum, significantly streamline) the onerous Hospital Consumer Assessment of Healthcare Providers and Systems (patient satisfaction) survey of hospitals, as the quality of the instrument and use of the results have degraded due to low response rates.</li><li>Support quality and patient safety while reducing burdens by reducing the required reporting of electronic clinical quality measures to a more targeted set of core measures.</li><li>Remove the requirement for hospitals to report reflecting screening for social determinants of health measures that are not linked to better outcomes.</li><li>Eliminate the mandatory requirement for Accountable Care Organizations to report quality data electronically, versus allowing reporting via a web interface.</li><li>Eliminate the Hospital Readmission Reduction Program, as performance has topped out.</li><li>Suspend the Medicare hospital star ratings program as the methodology is inadequate, including distorted comparisons of hospital performance and a significant time lag.</li><li>Remove quality measures from the inpatient psychiatric quality reporting program that are not directly relevant to inpatient psychiatric care, such as whether the facility offers smoking cessation services.</li><li>Remove all structural measures from hospital quality reporting programs that have little evidence tying their use to better care or outcomes, including the Patient Safety Structural Measure, Health Equity Structural Measure and Age-Friendly Hospital measure.</li><li>Remove (or, at a minimum, make voluntary) the reporting of hybrid hospital readmissions/mortality measures and hip/knee arthroplasty patient-reported outcome measures due to significant feasibility issues.</li></ol><h3>Surveys and Accreditation</h3><ol start="66"><li>Minimize in-person hospital surveys for low-risk complaints and resume them virtually.</li><li>Permanently adopt concurrent validation surveys for CMS accrediting organizations, eliminating duplicative “lookback” surveys that require a full resurvey of hospital compliance with CoPs.</li><li>Allow hospitals time to ensure adequate staffing and resources during surveys without compromising the integrity of those surveys by eliminating the prohibition on accrediting organizations providing same-day notification of a survey.</li><li>Eliminate punitive removals of “deemed status” when a hospital has one or more condition-level citations on a validation survey, which is unnecessary for adequate oversight. </li></ol><h3>Other</h3><ol start="70"><li>Repeal the nursing home staffing rule that would not improve quality or safety and would require nearly 80% of all nursing homes — including those with five stars — to increase staffing.</li><li>Revise the obstetrical care CoP by removing requirements that are not directly relevant to improving obstetrical care and redundant with existing requirements, such as requirements focused on non-obstetrical emergencies, supplies and training.</li><li>Reduce unnecessary burden while ensuring adequate emergency response preparation by reducing the number of required hospital emergency preparedness drills to once a year.</li><li>Remove the requirement that hospitals provide translation services for patients in 15 different languages and instead allow hospitals to ensure adequate translation for the populations they serve.</li><li>Enable inpatient psychiatric facilities (IPFs) to provide appropriate monitoring of patients at risk of suicide without overburdening the workforce or adding unnecessary costs by eliminating the requirement that IPFs have one-to-one monitoring of patients at risk of suicide.</li><li>Eliminate 42 CFR Part 2 requirements providing special privacy protections for behavioral health patients and protect their privacy under HIPAA.</li><li>Eliminate the Occupational Safety and Health Administration (OSHA) “walkaround rule” that allows union representatives to accompany OSHA inspectors.</li><li>Enable hospitals to reduce costs by limiting the requirement to purchase supplies through CMS-approved vendors to only medical devices and other aspects of direct patient care and exempting non-clinical items such as office furniture and supplies.</li><li>Support providers’ access to cheaper drugs by enforcing rules to prevent gaming of patents and other policies that stifle pharmaceutical competition. </li></ol><h2>TELEHEALTH </h2><p>As technology and consumer preferences have evolved, more care can safely be delivered via telehealth. However, numerous regulations restrict the use of virtual care. Addressing the following areas would not only reduce unnecessary burdens on the health care system but also improve clinician capacity, increasing access to care. </p><ol start="79"><li>Remove telehealth originating site restrictions to enable patients to receive telehealth in their homes.</li><li>Remove telehealth geographic site restrictions to enable beneficiaries in non-rural areas to have the same access to virtual care as those in rural areas.</li><li>Remove restrictions on telehealth modalities to enable a wider range of services (e.g., audio only) to be safely delivered via telehealth.</li><li>Similarly, remove restrictions on the provider types eligible to perform telehealth.</li><li>Remove restrictions on the types of distant sites eligible to perform telehealth services.</li><li>Allow hospital outpatient departments to bill for telehealth services when patients are in their homes (assuming statutes are updated to allow for telehealth to patients' homes permanently).</li><li>Remove the in-person visit requirements for behavioral health telehealth.</li><li>Remove restrictions to allow new patients to receive remote physiologic monitoring.</li><li>Remove case-by-case approval of new telehealth services; instead, include all Medicare-covered services as eligible telehealth services and remove them on a case-by-case basis.</li><li>Remove in-person visit requirements prior to prescribing controlled substances by establishing a special registration process for virtual prescribers.</li><li>Remove requirements for hospice recertification to be completed in person to allow for telehealth-based recertification.</li></ol><h2>WORKFORCE</h2><p>The health care system’s greatest asset is our workforce. Unfortunately, doctors, nurses, technicians and others are increasingly burned out and leaving the profession, often citing excessive administrative burden that pulls them away from patient care. The following regulatory relief ideas would support our workforce.</p><ol start="90"><li>Eliminate the telehealth physician home address reporting requirement, which compromises workforce safety.</li><li>Remove requirements for outpatient physical therapy plans of care to be signed off by a physician or nurse practitioner every 90 days.</li><li>Reform nursing and allied health education payments to relax the CMS interpretation of "director control.”</li><li>Eliminate or raise the tax-free limit of $5,250 on employer-provided funds spent to train employees in high-demand services like radiology.</li><li>Repeal the Federal Trade Commission's Non-Compete Clause Rule.</li><li>Reform rules related to “fair market value” to ensure that hospitals can obtain access to necessary specialist services.</li><li>Eliminate nurse practitioner practice limitations that are more restrictive under CMS rules than under state licensure.</li><li>Promote medical licensure reciprocity to allow practitioners to work across state lines.</li><li>Do not promulgate Occupational Safety and Health Administration federal workplace violence regulations that would be duplicative of the rigorous accreditation requirements hospitals already face and add an administrative burden.</li><li>Reduce unnecessary costs in the system by pursuing medical liability reform by eliminating joint and several liability.</li><li>Similarly, cap non-economic and punitive damages as part of medical liability. </li></ol></div></div></div></div> Mon, 14 Jul 2025 14:09:16 -0500 Letter/Comment /lettercomment/2025-07-08-aha-opposes-house-bill-proposing-expand-physician-owned-hospitals <p>July 8, 2025</p><table><tbody><tr><td>The Honorable Beth Van Duyne<br>U.S. House of Representatives<br>1725 Longworth House Office Building<br>Washington, DC 20515</td><td>The Honorable Henry Cuellar<br>U.S. House of Representatives<br>2308 Rayburn House Office Building<br>Washington, DC 20515</td></tr></tbody></table><p>Dear Representatives Van Duyne and Cuellar:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) writes to express our opposition to H.R. 4002, the Patient Access to Higher Quality Health Care Act.</p><p>If enacted, H.R. 4002 would skew the health care marketplace in favor of physicians who self-refer patients to hospitals they own, and it would destabilize health care access in communities while failing to improve access to quality care.</p><p>H.R. 4002 would result in additional gaming of the Medicare program, jeopardize patient access to emergency care, potentially harm sicker and lower-income patients, and severely damage the safety-net provided by full-service community hospitals across the nation.</p><p>Our member hospitals and health systems welcome competition; however, physician self-referral is the antithesis of fair competition. This problematic practice allows physicians to steer their most profitable cases to facilities they own — facilities that often call 9-1-1 to handle their emergencies and are often located in the most affluent areas. By providing the highest-paying procedures to the best-insured patients, physician owners inflate health care costs and drain essential resources from community hospitals, which depend on a balance of services and patients to provide indispensable treatment, such as behavioral health and trauma care. By increasing the presence of these self-referral arrangements, H.R. 4002 would destabilize community care.</p><p>Since the Medicare Modernization Act of 2003, Congress has supported ending the egregious and costly practice of physician self-referral to hospitals they own. Current law represents a compromise that (1) allows existing physician-owned hospitals to continue to treat Medicare patients, (2) permits the expansion of those physician-owned hospitals that meet communities’ needs for additional hospital capacity and treat low-income patients, and (3) prohibits Medicare from covering services in any new physician-owned hospitals (POHs) established after Dec. 31, 2010. Congress established these guardrails to protect the Medicare program from overutilization, patient steering and harmful patient selection practices that POHs employ. Data have shown time and again that POHs select only the healthiest and most profitable patients, serving lower proportions of Medicaid beneficiaries, dual-eligible patients and uncompensated care than full-service acute care hospitals. The Congressional Budget Office, the Medicare Payment Advisory Commission and the Centers for Medicare & Medicaid Services have concluded that physician self-referral leads to greater per capita utilization of services and higher costs for the Medicare program, among other negative impacts.</p><p>For these reasons, the AHA strongly opposes expansion of POHs — by either creating new categories of exceptions or allowing existing POHs to expand — and cannot support H.R. 4002. Congress should maintain current law, preserve the ban on physician self-referrals to new POHs, and retain restrictions on the growth of existing POHs.</p><p>Sincerely,<br>/s/<br>Lisa Kidder Hrobsky<br>Senior Vice President, Advocacy and Political Affairs</p> Tue, 08 Jul 2025 14:17:59 -0500 Letter/Comment /lettercomment/2025-07-07-aha-supports-bipartisan-resident-physician-shortage-reduction-act <div class="container"><div class="row"><div class="col-md-8"><p>July 2, 2025</p><div class="row"><div class="col-md-6"><p>The Honorable Terri A. Sewell<br>U.S. House of Representatives<br>1035 Longworth House Office Building<br>Washington, DC 20515</p></div><div class="col-md-6"><p>The Honorable Brian Fitzpatrick<br>U.S. House of Representatives<br>271 Cannon House Office Building<br>Washington, DC 202515</p></div></div><p>Dear Representatives Sewell and Fitzpatrick:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) writes to express our support for your legislation, H.R. 3890, the Resident Physician Shortage Reduction Act of 2025. Your bipartisan bill would add 14,000 Medicare-funded residency positions over seven years, thereby helping to alleviate ongoing physician shortages that threaten patients’ access to care.</p><p>Congress established graduate medical education (GME) funding to ensure an adequate supply of well-trained physicians. However, the current cap on residency slots, established in the Balanced Budget Act of 1997, restricts the number of residency slots for which hospitals may receive direct GME funding. A cap also limits the number of residents that hospitals may include in their ratios of residents-to-beds, which affects indirect medical education (IME) payments.</p><p>The bill would direct the Centers for Medicare & Medicaid Services (CMS) to increase the number of slots by 2,000 annually from 2026 through 2032. If CMS determines that there are remaining slots available after 2032, it must conduct additional distribution rounds until all 14,000 slots have been distributed. While an individual hospital may not receive more than 75 of these newly available slots, the bill would authorize CMS to increase this hospital-specific limitation if more slots are available than eligible applications.</p><p>The bill allots one-third of the slots each year to teaching hospitals that train at least 10 residents above their applicable caps and train at least 25% of their residents in primary care and general surgery. A hospital receiving slots under this mechanism would be required to continue to train at least 25% of its residents in primary care and general surgery for a five-year period. The slots would be distributed based on each hospital’s proportionate share of residents training above its cap compared to the total number of residents training above all hospital caps. An individual hospital’s receipt of slots under this first mechanism would not affect its ability to apply for slots from the remaining pool of slots.</p><p>Two-thirds of the slots each year would be available for teaching hospitals through a second mechanism. For this pool of slots, CMS must consider the likelihood of a teaching hospital filling the positions within the first five cost-reporting periods beginning after the effective date of the direct GME and/or IME cap increase. For this pool of slots, the legislation does not allow any new reimbursable Medicare slots to be used for residents currently in training above hospitals’ applicable caps.</p><p>For the second mechanism, CMS must provide a minimum of 10% of the awarded slots to each of the following four priority categories:</p><ul><li>Hospitals located in a rural area, an area with a rural-urban commuter code of 4.0 or greater, a sole community hospital or hospital located within 10 miles of a sole community hospital, or a hospital that has a rural training track as of 2031.</li><li>Hospitals training residents above their direct GME and IME caps, taking into account cap increases and reductions previously made to hospitals through slot redistribution programs.</li><li>Hospitals located in states with new medical schools or locations/branch campuses as of Jan. 1, 2000.</li><li>Hospitals that serve areas designated as federal health professional shortage areas, with priority given to hospitals affiliated with historically Black medical schools or a professional or graduate institution listed in the Higher Education Act as promoting opportunities for Black Americans.</li></ul><p>New slots would be reimbursed at a hospital’s otherwise applicable per-resident amount for GME purposes and using the usual adjustment factor for IME reimbursement purposes.</p><p>Recognizing the urgent need for physicians in rural areas of the nation, the bill would authorize $63.5 million in grant funding for geographically rural hospitals seeking to start residency programs. Rural hospitals would be eligible to apply for grants that support the costs of starting a residency program, recruiting and retaining qualified faculty, attracting residents, and supporting the additional costs of curriculum development and training.</p><p>Additionally, the bill would require the Comptroller General to study and report to Congress on strategies to increase the diversity of the health professional workforce.</p><p>The AHA is firmly committed to ensuring hospitals’ staff and governance reflect the communities that they serve, and your bill would support our efforts. We are grateful for your strong leadership in introducing this crucial legislation. The AHA stands ready to work with you to ensure its enactment.</p><p>Sincerely,</p><p>/s/</p><p>Lisa Kidder Hrobsky<br>Senior Vice President, Advocacy and Political Affairs</p></div><div class="col-md-4"><div class="sticky"><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2025/07/AHA-Supports-Bipartisan-Resident-Physician-Shortage-Reduction-Act.pdf" target="_blank" title="Click here to download the AHA Supports Bipartisan Resident Physician Shortage Reduction Act letter.">Download the Letter PDF</a></div><a href="/system/files/media/file/2025/07/AHA-Supports-Bipartisan-Resident-Physician-Shortage-Reduction-Act.pdf" target="_blank" title="Click here to download the AHA Supports Bipartisan Resident Physician Shortage Reduction Act letter."><img src="/sites/default/files/inline-images/Page-1-AHA-Supports-Bipartisan-Resident-Physician-Shortage-Reduction-Act.png" data-entity-uuid="ab5e0c60-541f-48dc-8ab2-eb0bc0bdf158" data-entity-type="file" alt="AHA Supports Bipartisan Resident Physician Shortage Reduction Act letter page 1." width="688" height="900"></a></div></div></div></div> div.sticky { position: sticky; top: 0; } Mon, 07 Jul 2025 15:05:55 -0500 Letter/Comment /lettercomment/2025-06-29-aha-urges-senate-amend-budget-reconciliation-bill-protect-access-care <p>June 29, 2025</p><p>Dear Senator:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) writes to share our very serious concerns with the amendment in the nature of a substitute for the One Big Beautiful Bill Act (OBBBA) (H.R. 1) that is being considered by the Senate. <strong>We welcome the opportunity to work with you to amend the legislation before its final passage in the Senate.</strong></p><p>The Medicaid program provides health insurance coverage for 72 million Americans, including children, pregnant women, the elderly, the disabled and millions of working Americans. A review by the Congressional Budget Office (CBO) of the Medicaid provisions in the Senate bill estimates cuts of $930 billion from the program as well as the loss of coverage for 11.8 million Americans. The magnitude of nearly a trillion-dollar reduction to the Medicaid program cannot be characterized solely as waste, fraud and abuse. The real-life consequences of these reductions will result in irreparable harm to access to care for all Americans and undermine the ability of hospitals and health systems to care for our most vulnerable patients.</p><p>This legislation will also cause millions of Americans to be displaced from insured to uninsured status due to changes in Medicaid policies, as well as those impacting the health insurance marketplaces. This loss of coverage will result in additional uncompensated care for hospitals and health systems, which will affect their ability to serve all patients. There will be service line reductions and staff reductions, resulting in longer waiting times in emergency departments and for other essential services, and could ultimately lead to facility closures, especially in rural and underserved areas.</p><p>The Senate legislation includes drastic limitations on the legal use of provider taxes and state-directed payments (SDPs). These changes in provider taxes, which states use to support their providers, and SDPs, which are used in managed care to make additional payments to providers to achieve a state’s Medicaid program quality goals, will result in significant reductions to hospital payments. These substantial policy changes far exceed the House-passed legislation. In a matter of weeks, the score for the policy changes related to SDP and provider tax changes went from $161 billion in Medicaid reductions in the House bill to $340 billion in the Senate bill, which will result in direct decreases in provider payments.</p><p>Provider taxes and SDPs allow hospitals to bridge the chronic and historic underpayment by Medicaid for the care they deliver. For example, in 2023, hospitals experienced a -42% Medicaid margin for inpatient obstetrics care and a -44.9% Medicaid margin for outpatient obstetrics services. Even with states utilizing provider taxes to fund their programs and implementing SDPs to help offset underpayments, in 2023, Medicaid fee-for-service reimbursement paid less than 58 cents for every dollar that hospitals spent caring for Medicaid patients, and Medicaid managed care organizations paid less than 65 cents over the same period. Medicaid underpaid hospitals and health systems nationwide by $27.5 billion in 2023.</p><p>It must be stated — once again — that Medicaid provider taxes are legitimate mechanisms to help states fund their programs, have been in use for decades, and are thoroughly vetted at both the state and federal levels. The CBO estimates that placing additional restrictions on the use of this critical tool will, along with the other policy changes in the legislation, force states to make significant changes. “CBO expects that in response to those provisions, states would modify their Medicaid or state-funded insurance programs to curtail their spending by reducing provider payment rates, reducing the scope or amount of optional services, and reducing Medicaid enrollment.”<sup>1</sup></p><p>According to AHA estimates of the Senate version of the OBBBA, the provider tax changes alone will result in a loss of federal payments to hospitals of $232 billion over 10 years.</p><p>We appreciate the Senate taking these concerns into consideration. We look forward to working with you to modify the legislation to mitigate the considerable structural changes to the Medicaid program that will result in negative impacts to beneficiaries, hospitals and our communities.</p><p>Sincerely,</p><p>/s/</p><p>Rick Pollack<br>President and CEO</p><div><hr><div id="ftn1"><p><sup>1</sup> <a href="https://www.cbo.gov/system/files/2025-06/Arrington-Guthrie-Letter-Medicaid.pdf">https://www.cbo.gov/system/files/2025-06/Arrington-Guthrie-Letter-Medicaid.pdf</a> </p></div></div> Sun, 29 Jun 2025 19:03:29 -0500 Letter/Comment /2025-06-18-aha-recommendations-fy-2026-senate-appropriations-funding-health-care-programs <p>June 18, 2025</p><table><tbody><tr><td>The Honorable Shelley Moore Capito<br>Chair<br>United States Senate<br>Subcommittee on Labor, Health and <br>Human Services, Education, and<br>Related Agencies<br>Committee on Appropriations<br>Washington, DC 20510</td><td>The Honorable Tammy Baldwin<br>Ranking Member<br>United States Senate<br>Subcommittee on Labor, Health and<br>Human Services, Education and<br>Related Agencies<br>Committee on Appropriations<br>Washington, DC 20510</td></tr></tbody></table><p> </p><p>Dear Chair Capito and Ranking Member Baldwin:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinical partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) writes regarding funding for health care programs for fiscal year (FY) 2026.</p><p>As you begin drafting the FY 2026 appropriations bill, we ask you to consider funding for health care programs that have proven successful in improving access to quality health care for patients and communities across America.</p><h2>Strengthening the Health Care Workforce</h2><p>Recruitment and retention of health care professionals are ongoing challenges and expenses for many hospitals. Nearly 70% of the primary health professional shortage areas are in rural or partially rural areas. Hospitals and health systems need a robust and highly qualified staff to handle medical care in emergencies. To achieve this goal, targeted programs that help address workforce shortages in rural communities should be supported and expanded. Workforce policies and programs also should encourage nurses and other allied professionals to practice at the top of their licenses. We respectfully request your support of the following programs.</p><ul><li><strong>Health Professions and Workforce Development Programs. </strong>The health care workforce crisis facing our nation necessitates continued investment in discretionary programs that address workforce challenges. Health professions programs support the recruitment of individuals into the allied health profession to help address the challenges rural and underserved communities face in accessing primary care providers. <strong>The AHA supports level funding for the Health Resources and Services Administration (HRSA) Title VII health professions and Title VIII nursing workforce development programs.</strong></li><li><strong>Primary Care Medicine, Pediatric Subspecialty Loan Repayment, Substance Use Disorder Treatment and Recovery Loan Repayment Program, and Oral Health Training programs.</strong> These programs help improve health care access and quality in underserved areas by training general internists, family medicine practitioners, general pediatricians, pediatric subspecialists, oral health providers, physician assistants and expanding behavioral health services. <strong>The AHA supports level funding over last year’s enacted level for these programs.</strong></li><li><strong>National Health Service Corps (NHSC). </strong>The NHSC awards scholarships to health professions students and assists graduates of health professions programs with loan repayment in return for an obligation to provide health care services in underserved rural and urban areas. <strong>The AHA supports continued discretionary funding for the NHSC. The AHA also believes that substantial mandatory funding is a necessary investment in this critical program.</strong></li></ul><h2>Maternal and Child Health</h2><p>Maternal and child health is essential for ensuring the well-being of families and communities, as early medical care can prevent complications and support lifelong health. Hospitals play a crucial role by providing specialized care, safe delivery environments and essential health services that promote healthy pregnancies and child development.</p><ul><li><strong>Children’s Hospitals Graduate Medical Education (CHGME). </strong>The CHGME program supports graduate medical education programs at children’s hospitals that train resident physicians. The purpose of the program is to provide 59 independent children’s hospitals with funds to train pediatricians and pediatric specialists. Freestanding children’s hospitals typically treat very few Medicare patients and, therefore, do not receive Medicare funding to support medical training of residents; the CHGME program helps fill this need. In addition to teaching the next generation of physicians, these hospitals provide lifesaving care to many children with complex medical needs. Currently, CHGME hospitals train 51% of all general pediatrics residents and over half (53%) of all pediatric subspeciality residents and fellows who care for children living in all 50 states. Unlike Medicare’s GME program, CHGME is funded through annual appropriations. <strong>The AHA supports funding the CHGME program in FY 2026 at $778 million.</strong></li><li><strong>Maternal and Child Health Block Grant (MCHBG). </strong>The Title V MCHBG is a funding source used to address the most critical, pressing and unique needs of maternal and child health populations in each state, territory and jurisdiction of the United States. The program helps states ensure access to quality maternal and child health care services, especially for those with low incomes or with limited access to care. The MCHBG program supports the State MCHBG program, Special Projects of Regional and National Significance, and Community Integrated Service Systems grants. According to data gathered by HRSA, the State MCHBG Program supports approximately 93% of pregnant women, 99% of infants and 61% of children. Improving maternal and child health is a major priority for the AHA<strong>. The AHA supports adequate funding for the Title V MCHBG in FY 2026.</strong></li><li><strong>Healthy Start Program. </strong>The Healthy Start program provides support for high-risk pregnant women, infants and families in communities with exceptionally high rates of infant mortality, including health care services, such as those focused on reducing maternal mortality, as well as the socioeconomic factors of poverty, education and access to care. <strong>The AHA supports level funding for FY 2026.</strong></li><li><strong>Emergency Medical Services for Children. </strong>This valuable program is designed to provide specialized emergency care for children through improved availability of child-appropriate equipment in ambulances and emergency departments. In addition, the program supports training to prevent injuries to children and to educate emergency medical technicians, paramedics and other emergency medical care providers. <strong>The AHA supports adequate funding for FY 2026.</strong></li></ul><h2>Rural Health</h2><p>Hospitals and health systems are the lifeblood of their communities and are committed to ensuring local access to health care. At the same time, many hospitals, including those in rural areas, continue to experience unprecedented challenges that jeopardize access and services. These include workforce shortages, high costs of prescription drugs, and continued severe underpayment by Medicare and Medicaid.</p><ul><li><strong>The Medicare Rural Hospital Flexibility (Flex) Grant Program. </strong>The Flex program improves hospital-based health care access for rural communities through working with Critical Access Hospitals (CAHs), emergency medical services, clinics and health professionals. <strong>AHA requests level funding in FY 2026</strong>.</li><li><strong>State Offices of Rural Health (SORH). </strong>SORHs help solve rural health challenges by providing technical assistance to organizations in rural communities, including rural hospitals and clinics, rural providers, emergency medical service providers and local governments, among others. <strong>AHA requests level funding in FY 2026.</strong></li><li><strong>Rural Health Outreach Grants.</strong> These grants improve rural community health by focusing on quality improvement, increased health care access, care coordination, and service integration. This program was created in recognition of the unique challenges faced by rural communities in accessing quality health care services. <strong>AHA requests level funding in FY 2026.</strong></li><li><strong>Rural Hospital Stabilization Program (RHSP).</strong> The RHSP is designed to support rural hospitals facing financial challenges by helping them expand or enhance health care services to meet community needs. <strong>AHA requests level funding for FY 2026.</strong></li><li><strong>Rural Health Policy Development.</strong> This funding supports several programs offering information and technical assistance for health care improvement in rural communities, including the Rural Health Clinic (RHC) Technical Assistance Program to analyze key regulatory, programmatic and clinical issues facing RHCs. <strong>AHA requests level funding.</strong></li><li><strong>Rural Communities Opioid Response Program (RCORP).</strong> The RCORP aims to reduce the morbidity and mortality of substance use disorder, including opioid use disorder, in high-risk rural communities. <strong>AHA requests level funding.</strong></li><li><strong>Rural Residency Program.</strong> The Rural Residency Planning and Development program seeks to expand the number of rural residency training programs, increase the number of physicians training in rural settings, and subsequently increase the number of physicians choosing to practice in rural areas. <strong>AHA requests level funding.</strong></li></ul><h2>Disaster Preparedness</h2><p>When disaster strikes, people turn to hospitals for help. We urge Congress to invest in programs that ensure hospitals and health systems can respond effectively in the case of emergencies and maintain critical operations that provide lifesaving care.</p><ul><li><p><strong>Hospital Preparedness Program (HPP). </strong>Since 2002, the HPP has provided critical funding and other resources to states and other jurisdictions to aid hospitals’ response to a wide range of emergencies. The HPP has allowed for enhanced planning and response; improved integration of public and private sector emergency planning to increase the preparedness, response and surge capacity of hospitals; and improved state and local infrastructures to help health systems and hospitals prepare for public health emergencies.<br><br>Funding for the HPP has not kept pace with the ever-changing and growing threats faced by hospitals, health systems and their communities. Furthermore, in recent years, hospitals have received only a fraction of the HPP funds. In particular, the vast majority of HPP funds support the sub-state Health Care Coalitions, regional collaborations between health care organizations, emergency management, public health agencies and other private partners.</p><p><strong>The AHA urges Congress to maintain level funding for this program to ensure that the health care infrastructure is ready to respond to future crises.</strong></p></li></ul><h2>Medical Research</h2><ul><li><strong>National Institutes of Health (NIH). </strong>The NIH plays a crucial role in supporting academic medical centers by funding groundbreaking research, driving medical innovation and training the next generation of health care professionals. Its grants and resources enable institutions to advance scientific discoveries, improve patient care and tackle complex health challenges. <strong>AHA supports appropriate funding for the NIH.</strong></li><li><strong>National Institute of Nursing Research.</strong> <strong>The AHA supports level funding for the National Institute of Nursing Research.</strong></li><li><strong>Centers for Disease Control and Prevention (CDC). </strong>The CDC is a vital partner to hospitals, patients and other health care providers in the prevention and monitoring of disease and emergency preparedness. Much of the research from the CDC demonstrates the value of prevention activities in averting health care crises, resulting in savings to Medicare, Medicaid and other health care programs. <strong>The AHA supports level funding for FY 2026</strong>.</li></ul><h2>Behavioral Health</h2><p>The AHA believes physical and mental health care are inextricably linked, and everyone deserves access to high-quality behavioral health care. We encourage the committee to support the following priorities within the Substance Use and Mental Health Services Administration (SAMHSA).</p><ul><li><strong>Certified Community Behavioral Health Clinics Expansion Grants (CCBHCs). </strong>CCBHCs help provide expanded access to mental health and substance use disorder services in communities and reduce emergency department usage by 60%. <strong>AHA supports level funding for FY 2026.</strong></li><li><strong>Substance Use Disorder Treatment and Recovery Loan Repayment (STAR) Program. </strong>The STAR Program provides for the repayment of education loans for individuals working in a full-time substance use disorder treatment job that involves direct patient care in either a Mental Health Professional Shortage Area or a county where the overdose death rate exceeds the national average. <strong>AHA requests level funding for FY 2026.</strong></li><li><strong>Preventing Burnout in the Health Workforce Program. </strong>For decades, health care professionals have faced greater rates of mental and behavioral health conditions, suicide and burnout than other professions while fearing the stigma and potential career repercussions of seeking care. A recent report found that 93% of health care workers reported stress, 86% reported anxiety, 77% reported frustration, 76% reported exhaustion and burnout, and 75% said they were overwhelmed.<a href="#_ftn1" title="">[1]</a> <strong>The AHA requests</strong> <strong>full funding for the Preventing Burnout in the Health Workforce Program.</strong></li></ul><h2>Other Priorities</h2><ul><li><strong>Unique Patient Identifier (UPI).</strong> The AHA supports the adoption of a UPI. Removing the prohibition on using federal funds to promulgate or adopt a national UPI would provide the Department of Health and Human Services the ability to explore solutions that accurately identify patients and link them with their correct medical records. America’s hospitals and health systems are committed to ensuring the highest quality care in a timely manner. Funding for a UPI would promote safe, efficient and timely care for patients while reducing administrative costs. We look forward to working with you to ensure appropriate patient identification methods.</li></ul><p>The AHA appreciates and is grateful for the support you have provided to vital health care programs, and we hope the committee will continue to support these funding priorities in FY 2026. We look forward to working with you.</p><p>Sincerely,</p><p>/s/</p><p>Stacey Hughes<br>Executive Vice President<br>__________</p><p><sup>1</sup> <a class="ck-anchor" href="/system/files/media/file/2022/09/Strengthening-the-Health-Care-Workforce-Complete-20220909.pdf" id="/system/files/media/file/2022/09/Strengthening-the-Health-Care-Workforce-Complete-20220909.pdf">/system/files/media/file/2022/09/Strengthening-the-Health-Care-Workforce-Complete-20220909.pdf</a> </p><p><br>Download the PDF below.</p> Wed, 18 Jun 2025 13:15:32 -0500 Letter/Comment /lettercomment/2025-06-18-aha-recommendations-fy-2026-house-appropriations-funding-health-care-programs <p>June 18, 2025</p><table><tbody><tr><td>The Honorable Robert Aderholt<br>Chair<br>U.S. House of Representatives<br>Subcommittee on Labor, Health and <br>Human Services, Education, and<br>Related Agencies<br>Committee on Appropriations<br>Washington, DC 20515</td><td>The Honorable Rosa DeLauro<br>Ranking Member<br>U.S. House of Representatives<br>Subcommittee on Labor, Health and<br>Human Services, Education and<br>Related Agencies<br>Committee on Appropriations<br>Washington, DC 20515</td></tr></tbody></table><p> </p><p>Dear Chairman Aderholt and Ranking Member DeLauro:</p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinical partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) writes regarding funding for health care programs for fiscal year (FY) 2026.</p><p>As you begin drafting the FY 2026 appropriations bill, we ask you to consider funding for health care programs that have proven successful in improving access to quality health care for patients and communities across America.</p><h2>Strengthening the Health Care Workforce </h2><p>Recruitment and retention of health care professionals are ongoing challenges and expenses for many hospitals. Nearly 70% of the primary health professional shortage areas are in rural or partially rural areas. Hospitals and health systems need a robust and highly qualified staff to handle medical care in emergencies. To achieve this goal, targeted programs that help address workforce shortages in rural communities should be supported and expanded. Workforce policies and programs also should encourage nurses and other allied professionals to practice at the top of their licenses. We respectfully request your support of the following programs.</p><ul><li><strong>Health Professions and Workforce Development Programs. </strong>The health care workforce crisis facing our nation necessitates continued investment in discretionary programs that address workforce challenges. Health professions programs support the recruitment of individuals into the allied health profession  to help address the challenges rural and underserved communities face in accessing primary care providers. <strong>The AHA supports level funding for the Health Resources and Services Administration (HRSA) Title VII health professions and Title VIII nursing workforce development programs.</strong></li><li><strong>Primary Care Medicine, Pediatric Subspecialty Loan Repayment, Substance Use Disorder Treatment and Recovery Loan Repayment Program, and Oral Health Training programs.</strong> These programs help improve health care access and quality in underserved areas by training general internists, family medicine practitioners, general pediatricians, pediatric subspecialists, oral health providers, physician assistants and expanding behavioral health services. <strong>The AHA supports level funding over last year’s enacted level for these programs.</strong></li><li><strong>National Health Service Corps (NHSC). </strong>The NHSC awards scholarships to health professions students and assists graduates of health professions programs with loan repayment in return for an obligation to provide health care services in underserved rural and urban areas. <strong>The AHA supports continued discretionary funding for the NHSC. The AHA also believes that substantial mandatory funding is a necessary investment in this critical program.</strong></li></ul><h2>Maternal and Child Health</h2><p>Maternal and child health is essential for ensuring the well-being of families and communities, as early medical care can prevent complications and support lifelong health. Hospitals play a crucial role by providing specialized care, safe delivery environments and essential health services that promote healthy pregnancies and child development.</p><ul><li><strong>Children’s Hospitals Graduate Medical Education (CHGME). </strong>The CHGME program supports graduate medical education programs at children’s hospitals that train resident physicians. The purpose of the program is to provide 59 independent children’s hospitals with funds to train pediatricians and pediatric specialists. Freestanding children’s hospitals typically treat very few Medicare patients and, therefore, do not receive Medicare funding to support medical training of residents; the CHGME program helps fill this need. In addition to teaching the next generation of physicians, these hospitals provide lifesaving care to many children with complex medical needs. Currently, CHGME hospitals train 51% of all general pediatrics residents and over half (53%) of all pediatric subspeciality residents and fellows who care for children living in all 50 states. Unlike Medicare’s GME program, CHGME is funded through annual appropriations. <strong>The AHA supports funding the CHGME program in FY 2026 at $778 million.</strong></li><li><strong>Maternal and Child Health Block Grant (MCHBG). </strong>The Title V MCHBG is a funding source used to address the most critical, pressing and unique needs of maternal and child health populations in each state, territory and jurisdiction of the United States. The program helps states ensure access to quality maternal and child health care services, especially for those with low incomes or with limited access to care. The MCHBG program supports the State MCHBG program, Special Projects of Regional and National Significance, and Community Integrated Service Systems grants. According to data gathered by HRSA, the State MCHBG Program supports approximately 93% of pregnant women, 99% of infants and 61% of children. Improving maternal and child health is a major priority for the AHA<strong>. The AHA supports adequate funding for the Title V MCHBG in FY 2026.</strong></li><li><strong>Healthy Start Program. </strong>The Healthy Start program provides support for high-risk pregnant women, infants and families in communities with exceptionally high rates of infant mortality, including health care services, such as those focused on reducing maternal mortality, as well as the socioeconomic factors of poverty, education and access to care. <strong>The AHA supports level funding for FY 2026.</strong></li><li><strong>Emergency Medical Services for Children. </strong>This valuable program is designed to provide specialized emergency care for children through improved availability of child-appropriate equipment in ambulances and emergency departments. In addition, the program supports training to prevent injuries to children and to educate emergency medical technicians, paramedics and other emergency medical care providers. <strong>The AHA supports adequate funding for FY 2026.</strong></li></ul><h2>Rural Health</h2><p>Hospitals and health systems are the lifeblood of their communities and are committed to ensuring local access to health care. At the same time, many hospitals, including those in rural areas, continue to experience unprecedented challenges that jeopardize access and services. These include workforce shortages, high costs of prescription drugs, and continued severe underpayment by Medicare and Medicaid.</p><ul><li><strong>The Medicare Rural Hospital Flexibility (Flex) Grant Program. </strong>The Flex program improves hospital-based health care access for rural communities through working with Critical Access Hospitals (CAHs), emergency medical services, clinics and health professionals. <strong>AHA requests level funding in FY 2026</strong>.</li><li><strong>State Offices of Rural Health (SORH). </strong>SORHs help solve rural health challenges by providing technical assistance to organizations in rural communities, including rural hospitals and clinics, rural providers, emergency medical service providers and local governments, among others. <strong>AHA requests level funding in FY 2026.</strong></li><li><strong>Rural Health Outreach Grants.</strong> These grants improve rural community health by focusing on quality improvement, increased health care access, care coordination, and service integration. This program was created in recognition of the unique challenges faced by rural communities in accessing quality health care services. <strong>AHA requests level funding in FY 2026.</strong></li><li><strong>Rural Hospital Stabilization Program (RHSP).</strong> The RHSP is designed to support rural hospitals facing financial challenges by helping them expand or enhance health care services to meet community needs. <strong>AHA requests level funding for FY 2026.</strong></li><li><strong>Rural Health Policy Development.</strong> This funding supports several programs offering information and technical assistance for health care improvement in rural communities, including the Rural Health Clinic (RHC) Technical Assistance Program to analyze key regulatory, programmatic and clinical issues facing RHCs. <strong>AHA requests level funding.</strong></li><li><strong>Rural Communities Opioid Response Program (RCORP).</strong> The RCORP aims to reduce the morbidity and mortality of substance use disorder, including opioid use disorder, in high-risk rural communities. <strong>AHA requests level funding.</strong></li><li><strong>Rural Residency Program.</strong> The Rural Residency Planning and Development program seeks to expand the number of rural residency training programs, increase the number of physicians training in rural settings, and subsequently increase the number of physicians choosing to practice in rural areas. <strong>AHA requests level funding.</strong></li></ul><h2>Disaster Preparedness</h2><p>When disaster strikes, people turn to hospitals for help. We urge Congress to invest in programs that ensure hospitals and health systems can respond effectively in the case of emergencies and maintain critical operations that provide lifesaving care.</p><ul><li><p><strong>Hospital Preparedness Program (HPP). </strong>Since 2002, the HPP has provided critical funding and other resources to states and other jurisdictions to aid hospitals’ response to a wide range of emergencies. The HPP has allowed for enhanced planning and response; improved integration of public and private sector emergency planning to increase the preparedness, response and surge capacity of hospitals; and improved state and local infrastructures to help health systems and hospitals prepare for public health emergencies. <br><br>Funding for the HPP has not kept pace with the ever-changing and growing threats faced by hospitals, health systems and their communities. Furthermore, in recent years, hospitals have received only a fraction of the HPP funds. In particular, the vast majority of HPP funds support the sub-state Health Care Coalitions, regional collaborations between health care organizations, emergency management, public health agencies and other private partners.</p><p><strong>The AHA urges Congress to maintain level funding for this program to ensure that the health care infrastructure is ready to respond to future crises.</strong></p></li></ul><h2><strong>Medical Research</strong></h2><ul><li> <strong>National Institutes of Health (NIH). </strong>The NIH plays a crucial role in supporting academic medical centers by funding groundbreaking research, driving medical innovation and training the next generation of health care professionals. Its grants and resources enable institutions to advance scientific discoveries, improve patient care and tackle complex health challenges. <strong>AHA supports appropriate funding for the NIH.</strong></li><li><strong>National Institute of Nursing Research.</strong> <strong>The AHA supports level funding for the National Institute of Nursing Research.</strong></li><li><strong>Centers for Disease Control and Prevention (CDC). </strong>The CDC is a vital partner to hospitals, patients and other health care providers in the prevention and monitoring of disease and emergency preparedness. Much of the research from the CDC demonstrates the value of prevention activities in averting health care crises, resulting in savings to Medicare, Medicaid and other health care programs. <strong>The AHA supports level funding for FY 2026</strong>.</li></ul><h2>Behavioral Health </h2><p>The AHA believes physical and mental health care are inextricably linked, and everyone deserves access to high-quality behavioral health care. We encourage the committee to support the following priorities within the Substance Use and Mental Health Services Administration (SAMHSA).</p><ul><li> <strong>Certified Community Behavioral Health Clinics Expansion Grants (CCBHCs). </strong>CCBHCs help provide expanded access to mental health and substance use disorder services in communities and reduce emergency department usage by 60%. <strong>AHA supports level funding for FY 2026.</strong></li><li><strong>Substance Use Disorder Treatment and Recovery Loan Repayment (STAR) Program. </strong>The STAR Program provides for the repayment of education loans for individuals working in a full-time substance use disorder treatment job that involves direct patient care in either a Mental Health Professional Shortage Area or a county where the overdose death rate exceeds the national average. <strong>AHA requests level funding for FY 2026.</strong></li><li><strong>Preventing Burnout in the Health Workforce Program. </strong>For decades, health care professionals have faced greater rates of mental and behavioral health conditions, suicide and burnout than other professions while fearing the stigma and potential career repercussions of seeking care. A recent report found that 93% of health care workers reported stress, 86% reported anxiety, 77% reported frustration, 76% reported exhaustion and burnout, and 75% said they were overwhelmed.<a href="#_ftn1" title="">[1]</a> <strong>The AHA requests</strong> <strong>full funding for the Preventing Burnout in the Health Workforce Program.</strong></li></ul><h2>Other Priorities</h2><ul><li><strong>Unique Patient Identifier (UPI).</strong> The AHA supports the adoption of a UPI. Removing the prohibition on using federal funds to promulgate or adopt a national UPI would provide the Department of Health and Human Services the ability to explore solutions that accurately identify patients and link them with their correct medical records. America’s hospitals and health systems are committed to ensuring the highest quality care in a timely manner. Funding for a UPI would promote safe, efficient and timely care for patients while reducing administrative costs. We look forward to working with you to ensure appropriate patient identification methods.</li></ul><p>The AHA appreciates and is grateful for the support you have provided to vital health care programs, and we hope the committee will continue to support these funding priorities in FY 2026. We look forward to working with you.</p><p>Sincerely,</p><p>/s/</p><p>Stacey Hughes<br>Executive Vice President<br>__________</p><p><a href="#_ftnref1" title=""><sup>1</sup></a> <a href="/system/files/media/file/2022/09/Strengthening-the-Health-Care-Workforce-Complete-20220909.pdf">/system/files/media/file/2022/09/Strengthening-the-Health-Care-Workforce-Complete-20220909.pdf</a> </p><p><br>Download the PDF below.</p> Wed, 18 Jun 2025 12:42:45 -0500 Letter/Comment