Letter/Comment

Letter/Comment / en Wed, 25 Jun 2025 22:56:56 -0500 Wed, 18 Jun 25 13:15:32 -0500 AHA Recommendations for FY 2026 Senate Appropriations Funding for Health Care Programs /2025-06-18-aha-recommendations-fy-2026-senate-appropriations-funding-health-care-programs June 18, 2025<table><tbody><tr><td>The Honorable Shelley Moore Capito Chair United States Senate Subcommittee on Labor, Health and&nbsp; Human Services, Education, and Related Agencies Committee on Appropriations Washington, DC 20510</td><td>The Honorable Tammy Baldwin Ranking Member United States Senate Subcommittee on Labor, Health and Human Services, Education and Related Agencies Committee on Appropriations Washington, DC 20510</td></tr></tbody></table>&nbsp;Dear Chair Capito and Ranking Member Baldwin: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.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.<h2>Strengthening the Health Care Workforce</h2>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.<ul><li>Health Professions and Workforce Development Programs.&nbsp;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. The AHA supports level funding for the Health Resources and Services Administration (HRSA) Title VII health professions and Title VIII nursing workforce development programs.</li><li>Primary Care Medicine, Pediatric Subspecialty Loan Repayment, Substance Use Disorder Treatment and Recovery Loan Repayment Program, and Oral Health Training programs. 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. The AHA supports level funding over last year’s enacted level for these programs.</li><li>National Health Service Corps (NHSC).&nbsp;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. 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.</li></ul><h2>Maternal and Child Health</h2>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.<ul><li>Children’s Hospitals Graduate Medical Education (CHGME).&nbsp;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. The AHA supports funding the CHGME program in FY 2026 at $778 million.</li><li>Maternal and Child Health Block Grant (MCHBG).&nbsp;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. The AHA supports adequate funding for the Title V MCHBG in FY 2026.</li><li>Healthy Start Program.&nbsp;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. The AHA supports level funding for FY 2026.</li><li>Emergency Medical Services for Children.&nbsp;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. The AHA supports adequate funding for FY 2026.</li></ul><h2>Rural Health</h2>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.<ul><li>The Medicare Rural Hospital Flexibility (Flex) Grant Program.&nbsp;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. AHA requests level funding in FY 2026.</li><li>State Offices of Rural Health (SORH).&nbsp;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. AHA requests level funding in FY 2026.</li><li>Rural Health Outreach Grants. 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. AHA requests level funding in FY 2026.</li><li>Rural Hospital Stabilization Program (RHSP). The RHSP is designed to support rural hospitals facing financial challenges by helping them expand or enhance health care services to meet community needs. AHA requests level funding for FY 2026.</li><li>Rural Health Policy Development. 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. AHA requests level funding.</li><li>Rural Communities Opioid Response Program (RCORP). The RCORP aims to reduce the morbidity and mortality of substance use disorder, including opioid use disorder, in high-risk rural communities.&nbsp;AHA requests level funding.</li><li>Rural Residency Program. 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. AHA requests level funding.</li></ul><h2>Disaster Preparedness</h2>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.<ul><li>Hospital Preparedness Program (HPP).&nbsp;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. 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.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.</li></ul><h2>Medical Research</h2><ul><li>National Institutes of Health (NIH).&nbsp;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. AHA supports appropriate funding for the NIH.</li><li>National Institute of Nursing Research. The AHA supports level funding for the National Institute of Nursing Research.</li><li>Centers for Disease Control and Prevention (CDC).&nbsp;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. The AHA supports level funding for FY 2026.</li></ul><h2>Behavioral Health</h2>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).<ul><li>Certified Community Behavioral Health Clinics Expansion Grants (CCBHCs).&nbsp;CCBHCs help provide expanded access to mental health and substance use disorder services in communities and reduce emergency department usage by 60%. AHA supports level funding for FY 2026.</li><li>Substance Use Disorder Treatment and Recovery Loan Repayment (STAR) Program.&nbsp;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.&nbsp;AHA requests level funding for FY 2026.</li><li>Preventing Burnout in the Health Workforce Program.&nbsp;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>&nbsp;The AHA requests&nbsp;full funding for the Preventing Burnout in the Health Workforce Program.</li></ul><h2>Other Priorities</h2><ul><li>Unique Patient Identifier (UPI). 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>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.Sincerely,/s/Stacey Hughes Executive Vice President __________1&nbsp;<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>&nbsp; Download the PDF below. Wed, 18 Jun 2025 13:15:32 -0500 Letter/Comment AHA Recommendations for FY 2026 House Appropriations Funding for Health Care Programs /lettercomment/2025-06-18-aha-recommendations-fy-2026-house-appropriations-funding-health-care-programs June 18, 2025<table><tbody><tr><td>The Honorable Robert Aderholt Chair U.S. House of Representatives Subcommittee on Labor, Health and&nbsp; Human Services, Education, and Related Agencies Committee on Appropriations Washington, DC 20515</td><td>The Honorable Rosa DeLauro Ranking Member U.S. House of Representatives Subcommittee on Labor, Health and Human Services, Education and Related Agencies Committee on Appropriations Washington, DC 20515</td></tr></tbody></table>&nbsp;Dear Chairman Aderholt and Ranking Member DeLauro: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.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.<h2>Strengthening the Health Care Workforce&nbsp;</h2>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.<ul><li>Health Professions and Workforce Development Programs.&nbsp;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 &nbsp;to help address the challenges rural and underserved communities face in accessing primary care providers. The AHA supports level funding for the Health Resources and Services Administration (HRSA) Title VII health professions and Title VIII nursing workforce development programs.</li><li>Primary Care Medicine, Pediatric Subspecialty Loan Repayment, Substance Use Disorder Treatment and Recovery Loan Repayment Program, and Oral Health Training programs. 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. The AHA supports level funding over last year’s enacted level for these programs.</li><li>National Health Service Corps (NHSC).&nbsp;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. 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.</li></ul><h2>Maternal and Child Health</h2>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.<ul><li>Children’s Hospitals Graduate Medical Education (CHGME).&nbsp;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. The AHA supports funding the CHGME program in FY 2026 at $778 million.</li><li>Maternal and Child Health Block Grant (MCHBG).&nbsp;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. The AHA supports adequate funding for the Title V MCHBG in FY 2026.</li><li>Healthy Start Program.&nbsp;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. The AHA supports level funding for FY 2026.</li><li>Emergency Medical Services for Children.&nbsp;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. The AHA supports adequate funding for FY 2026.</li></ul><h2>Rural Health</h2>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.<ul><li>The Medicare Rural Hospital Flexibility (Flex) Grant Program.&nbsp;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. AHA requests level funding in FY 2026.</li><li>State Offices of Rural Health (SORH).&nbsp;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. AHA requests level funding in FY 2026.</li><li>Rural Health Outreach Grants. 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. AHA requests level funding in FY 2026.</li><li>Rural Hospital Stabilization Program (RHSP). The RHSP is designed to support rural hospitals facing financial challenges by helping them expand or enhance health care services to meet community needs. AHA requests level funding for FY 2026.</li><li>Rural Health Policy Development. 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. AHA requests level funding.</li><li>Rural Communities Opioid Response Program (RCORP). The RCORP aims to reduce the morbidity and mortality of substance use disorder, including opioid use disorder, in high-risk rural communities.&nbsp;AHA requests level funding.</li><li>Rural Residency Program. 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. AHA requests level funding.</li></ul><h2>Disaster Preparedness</h2>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.<ul><li>Hospital Preparedness Program (HPP).&nbsp;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.&nbsp; 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.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.</li></ul><h2>Medical Research</h2><ul><li>&nbsp;National Institutes of Health (NIH).&nbsp;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. AHA supports appropriate funding for the NIH.</li><li>National Institute of Nursing Research. The AHA supports level funding for the National Institute of Nursing Research.</li><li>Centers for Disease Control and Prevention (CDC).&nbsp;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. The AHA supports level funding for FY 2026.</li></ul><h2>Behavioral Health&nbsp;</h2>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).<ul><li>&nbsp;Certified Community Behavioral Health Clinics Expansion Grants (CCBHCs).&nbsp;CCBHCs help provide expanded access to mental health and substance use disorder services in communities and reduce emergency department usage by 60%. AHA supports level funding for FY 2026.</li><li>Substance Use Disorder Treatment and Recovery Loan Repayment (STAR) Program.&nbsp;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.&nbsp;AHA requests level funding for FY 2026.</li><li>Preventing Burnout in the Health Workforce Program.&nbsp;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>&nbsp;The AHA requests&nbsp;full funding for the Preventing Burnout in the Health Workforce Program.</li></ul><h2>Other Priorities</h2><ul><li>Unique Patient Identifier (UPI). 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>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.Sincerely,/s/Stacey Hughes Executive Vice President __________<a href="#_ftnref1" title="">1</a>&nbsp;<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>&nbsp; Download the PDF below. Wed, 18 Jun 2025 12:42:45 -0500 Letter/Comment AHA Comments on the CMS and ASTP/ONC Request for Information Re: The Health Technology Ecosystem /lettercomment/2025-06-16-aha-comments-cms-and-astponc-request-information-re-health-technology-ecosystem June 16, 2024The Honorable Thomas Keane, M.D. Assistant Secretary for Technology Policy National Coordinator for Health Information Technology Department of Health and Human Services Attention: CMS-0042-NC P.O. Box 8013 Baltimore, MD 21244-8013The Honorable Stephanie Carlton Deputy Administrator and Chief of Staff Centers for Medicare &amp; Medicaid Services Department of Health and Human Services Attention: CMS-0042-NC P.O. Box 8013 Baltimore, MD 21244-8013Submitted ElectronicallyRE: CMS-0042-NC Request for Information; Health Technology EcosystemDear Assistant Secretary Keane and Deputy Administrator Carlton,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&nbsp;comment on the Centers for Medicare &amp; Medicaid Services (CMS) and Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC)&nbsp;Request for Information (RFI) regarding the Health Technology Ecosystem.We support the agencies’ goals of reducing barriers for data interoperability and fostering innovation to support better health outcomes. The AHA recognizes the pivotal role that health technology plays in care delivery today and its potential to transform the patient and provider experience in the future. From artificial intelligence (AI) to mobile apps, medical devices to electronic health records (EHRs) — technology supports improvements in quality and efficiency for patients, caregivers and providers. Moreover, we believe that technology and data interoperability have the potential to address some of the prevalent challenges confronting the health care ecosystem today, including provider burnout and staffing shortages driven by administrative burdens. We also recognize that the innovative applications of health information technology (IT) must be balanced with reasonable guardrails to protect sensitive patient data and ensure security and privacy. In addition, while health technology can make care more efficient, implementing new tools and standards often requires significant financial investment and workflow changes for health care providers. This makes it critical for policymakers to ensure that policy changes intended to spur adoption are scoped and paced sustainably.The AHA has several recommendations to improve health IT standards and infrastructure, increase beneficiary access to effective digital health tools, and advance data availability to improve health outcomes. Specifically, we recommend that CMS and ASTP/ONC:<ul><li>Foster a sustainable pace of standards implementation by continuing to develop ASTP/ONC’s United States Core Data for Interoperability vocabulary standards (USCDI), and extending the timeline to transition from USCDI version 3 to USCDI version 4 by an additional year (through calendar year (CY) 2028).</li><li>Collaborate across agencies to address broader infrastructure challenges associated with health IT adoption, such as lack of broadband, digital literacy training and reliable Wi-Fi access for rural and underserved communities.</li><li>Support reimbursement for the use of health technology by clarifying guidance on digital health and interprofessional consultation billing codes, and develop pathways to provide provisional payment for new technologies.</li><li>Promote accountability and engagement from payers on interoperability by requiring that impacted payers adopt and use certified payer application programming interfaces (APIs) and developing safety and security requirements for the Provider Directory APIs.</li><li>Repeal provider disincentives in the June 2024 final rule “21st Century Cures Act: Establishment of Disincentives for Healthcare Providers That Have Committed Information Blocking.” Under the final rule, hospitals and providers found to engage in information blocking may face excessive reductions in payment, which threatens access to services (particularly in rural and underserved areas).</li><li>Build additional infrastructure to provide oversight for Trusted Exchange Framework and Common Agreement (TEFCA), including establishing an attestation schedule for all qualified health information networks (QHINs)</li><li>Provide protections to ensure hospitals or health systems that have a QHIN that is suspended or terminated are not held liable for information blocking claims.</li><li>Advance administrative simplification efforts by establishing a standard transaction for clinical attachments to support claims.</li><li>Streamline current price transparency policies to remove complexity from the patient experience by focusing on options for patient estimates and other pricing information. Rely on No Surprises Act good faith estimates (GFEs) and advanced explanation of benefits (AEOBs) to provide patients with the most accurate estimates for their courses of care.</li><li>Provide incentives for technology investment to enable providers to transition to value-based arrangements.</li><li>Revert to previous thresholds (i.e., percentage threshold for the number of clinicians meeting certified electronic health record requirements) for the Medicare Shared Savings Program promoting interoperability measures.</li></ul>There are other areas relevant to the health technology ecosystem that were not directly addressed in the RFI, including cybersecurity. We included several health IT and cybersecurity-focused recommendations in our recent response to the Office of Management and Budget's RFI on deregulation, including modifying the HIPAA cybersecurity rule of December 2024 to make the requirements voluntary.1Our detailed comments are attached. We look forward to the opportunity to work with CMS, ASTP/ONC and the Department of Health and Human Services (HHS) to help realize technology’s full potential for improving health outcomes, fully engaging patients in managing their health and reducing administrative burden. Please contact me if you have questions, or feel free to have a member of your team contact Jennifer Holloman, AHA director of health IT policy, at&nbsp;<a href="mailto:jholloman@aha.org">jholloman@aha.org</a>.Sincerely,/s/Ashley Thompson Senior Vice President Public Policy Analysis and Development__________1 <a href="/system/files/media/file/2025/05/aha-response-to-omb-deregulation-rfi-letter-5-12-2025.pdf">/system/files/media/file/2025/05/aha-response-to-omb-deregulation-rfi-letter-5-12-2025.pdf</a> &nbsp; Mon, 16 Jun 2025 13:30:11 -0500 Letter/Comment AHA Comments on CMS Long-term Care Hospital FY 2026 Proposed Payment Rule /lettercomment/2025-06-10-aha-comments-cms-long-term-care-hospital-fy-2026-proposed-payment-rule June 10, 2025&nbsp;The Honorable Mehmet Oz, M.D. Administrator Centers for Medicare &amp; Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850Submitted ElectronicallyRe: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2026 Rates; Requirements for Quality Programs; and Other Policy Changes; 90 Fed. Reg. 18,002 (April 30, 2025).Dear Administrator Oz:On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 230 long-term care hospitals (LTCHs), our clinician partners — 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 comment on the Centers for Medicare &amp; Medicaid Services’ (CMS’) fiscal year (FY) 2026 LTCH prospective payment system (PPS) proposed rule. We are submitting separate comments on the rule’s inpatient PPS and Transforming Episode Accountability Model proposals.LTCHs care for some of the most complex and severely ill Medicare beneficiaries. As CMS points out in this rule, more than 90 percent of Medicare patients are dependent on a ventilator when arriving at an LTCH, have spent three or more days in an intensive care unit (ICU), or both. These patients have high rates of complex wounds, chronic illness, and other factors that make the LTCH patient population a uniquely resource-intensive group. For this reason, LTCHs maintain a deeply specialized expertise that enables them to care for these patients and maximize their chances of recovery. Indeed, many acute-care hospitals rely on LTCHs as partners to care for patients with these specific high-acuity needs by transferring them to LTCHs.Unfortunately, and as explained further in this letter, Medicare payment dynamics and related factors have caused a contraction of the LTCH field. This not only limits the ability of certain high-need patients from receiving care at an LTCH, but also strains the entire continuum of care as acute-care hospitals and other providers must find ways to care for these patients. This rule has several proposals that will exacerbate the ongoing difficulties within the LTCH field, particularly the large proposed increase in the high-cost outlier threshold. The AHA offers numerous recommendations to mitigate these effects, and we urge CMS to adopt them in the final rule.While we have concerns about the payment updates for this proposed rule, the AHA appreciates CMS’ efforts to alleviate the reporting burden on providers. Specifically, the AHA supports CMS’ proposal to remove four standardized patient assessment data elements (SPADEs) from the LTCH QRP and greatly appreciates CMS’ recognition of the need to balance administrative burden and value in quality measurement programs. By streamlining reporting requirements, CMS can free providers to focus on the quality and safety issues that matter the most to their patients. In addition, the AHA appreciates CMS’ efforts around deregulation and is responding to CMS’ Request for Information (RFI) on approaches and opportunities to streamline regulations and reduce administrative burdens on providers.Our detailed comments follow. Tue, 10 Jun 2025 15:45:47 -0500 Letter/Comment AHA Comments on CMS Inpatient Rehabilitation Facility FY 2026 Proposed Payment Rule /lettercomment/2025-06-10-aha-comments-cms-inpatient-rehabilitation-facility-fy-2026-proposed-payment-rule June 10, 2025The Honorable Mehmet Oz, M.D. Administrator Centers for Medicare &amp; Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850Re:&nbsp;Medicare Program; Inpatient Rehabilitation Facility Prospective Payment System for Federal Fiscal Year 2026 and Updates to the IRF Quality Reporting Program; 90 Fed. Reg. 18,534 (April 30, 2025).Dear Administrator Oz:On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 900 inpatient rehabilitation facilities (IRF), our clinician partners — more than 270,000 affiliated physicians, two 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 comment on the&nbsp;Centers for Medicare &amp; Medicaid Services’ (CMS)&nbsp;fiscal year (FY) 2026 IRF prospective payment system (PPS) proposed rule.IRFs play a critical role for Medicare beneficiaries in the continuum of care. These hospitals and units of acute-care hospitals care for patients with complex conditions as they undergo an intensive course of rehabilitation while being monitored and treated by a rehabilitation physician, which provides the optimal opportunity for maximum functional recovery following a serious injury or illness. The treatment provided by IRFs pays dividends down the road, allowing patients to return to their previous lives to the maximum extent possible.The AHA has concerns that Medicare payment updates continue to lag inflation and may not be adequate for the continued success of the IRF field. As discussed more thoroughly below, we urge CMS to examine its market basket and productivity adjustments to ensure appropriate annual updates. The AHA appreciates, however, CMS’ efforts to alleviate the reporting burden on providers. Specifically, the AHA supports CMS’ proposal to remove four standardized patient assessment data elements (SPADEs) from the IRF QRP and greatly appreciates CMS’ recognition of the need to balance administrative burden and value in quality measurement programs. By streamlining reporting requirements, CMS can free providers to focus on the quality and safety issues that matter the most to their patients. In addition, the AHA appreciates CMS’ efforts around deregulation and is responding to CMS’ Request for Information (RFI) on approaches and opportunities to streamline regulations and reduce administrative burdens on providers.Our detailed comments follow. Tue, 10 Jun 2025 15:31:24 -0500 Letter/Comment AHA Comments on CMS Skilled Nursing Facility FY 2026 Proposed Payment /lettercomment/2025-06-10-aha-comments-cms-skilled-nursing-facility-fy-2026-proposed-payment June 10, 2025The Honorable Mehmet Oz, M.D. Administrator Centers for Medicare &amp; Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850Re:&nbsp;Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program for Federal Fiscal Year 2026; 90 Fed. Reg. 18,950 (April 30, 2025).Dear Administrator Oz:On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 500 skilled-nursing facilities (SNFs), our clinician partners — more than 270,000 affiliated physicians, two 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 comment on the Centers for Medicare &amp; Medicaid Services’ (CMS) fiscal year (FY) 2026 SNF prospective payment system (PPS) proposed rule.SNFs play a critical role in the continuum of care; ensuring access to this frequently-utilized discharge destination is critical for patients continuing their recovery following a hospitalization. However, as the AHA highlighted in our comments on <a href="/lettercomment/2023-06-05-aha-comments-fy-2024-proposed-rule-skilled-nursing-facilities">prior rulemakings,</a> hospitals have faced increasing difficulty discharging patients to post-acute care, including SNFs. Staffing shortages and inadequate payment updates have contributed to the barriers to SNF care, as has the rapid expansion of beneficiary enrollment in Medicare Advantage (MA). The latter increases SNFs’ costs while reducing patient access and coverage, particularly through the inappropriate use of prior authorization. These shortfalls then place additional burden back on hospitals, which face extended lengths of stay for patients in need of post-acute care. While we appreciate that addressing concerns related to MA plans is outside of the scope of these comments, we encourage CMS to ensure that Traditional Medicare policies facilitate access to SNF services, rather than create barriers to care. Specifically, we urge CMS to provide adequate, timely payment updates for SNFs, including by re-examining the magnitude of its market basket updates and productivity adjustments.Additionally, AHA appreciates CMS’ efforts to alleviate reporting burden on providers. Specifically, the AHA supports CMS’ proposal to remove four standardized patient assessment data elements (SPADEs) from the SNF QRP and greatly appreciates CMS’ recognition of the need to balance administrative burden and value in quality measurement programs. By streamlining reporting requirements, CMS can free providers to focus on the quality and safety issues that matter the most to their patients. In addition, the AHA provides in this comment letter an overview of its response to CMS’ Request for Information (RFI) on approaches and opportunities to streamline regulations and reduce administrative burdens on providers.Our detailed comments follow. Tue, 10 Jun 2025 15:25:18 -0500 Letter/Comment AHA Comments on CMS FY 2026 Inpatient Prospective Payment System Proposed Rule /lettercomment/2025-06-10-aha-comments-cms-fy-2026-inpatient-prospective-payment-system-proposed-rule June 10, 2025The Honorable Mehmet Oz, M.D. Administrator Centers for Medicare &amp; Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W. Room 445-G Washington, DC 20201&nbsp;RE: CMS-1833-P, Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2026 Rates; Requirements for Quality Programs; and Other Policy Changes, (Vol. 90, No. 82), April 30, 2025.Dear Administrator Oz: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 comment on the Centers for Medicare &amp; Medicaid Services (CMS) hospital inpatient prospective payment system (PPS) proposed rule for fiscal year (FY) 2026. We are submitting separate comments on the agency’s proposed changes to the long-term care hospital PPS and Transforming Episode Accountability Model.Hospitals are the backbone of America’s healthcare system, providing essential, life-saving care 24/7 to millions of people each year. They serve as critical centers for emergency response, specialized treatment, and chronic disease management, while also acting as major employers and economic engines within their communities. As communities across the country face demand for health services, it is essential that Medicare payment policies support the sustainability and availability of these providers.To that end, we support several of the inpatient PPS proposed rule provisions, including the proposed increase in disproportionate share hospital (DSH) payments. We also appreciate the agency’s interest in deregulatory activities in the Medicare program and have submitted our comments through the request for information website. We also support several aspects of CMS’ quality-related proposals, including CMS’ recognition of the importance of striking an appropriate balance of burden and value in quality measurement programs and the removal of certain quality measures in the quality reporting programs.At the same time, we continue to have strong concerns about the proposed payment updates. The proposed net payment update of 2.4% is simply inadequate given the unrelenting financial headwinds faced by hospitals and health systems. We are particularly concerned with the inappropriately large productivity cut that is being proposed. We urge the agency to re-examine the magnitude of this adjustment and its impact on Medicare payments.Finally, we have concerns over the agency’s proposal to include Medicare Advantage patients in the Hospital Readmissions Reduction Program. Specifically, we are concerned that by including MA patients in calculating readmissions penalties, CMS effectively would be holding hospitals accountable for excessive and inappropriate coverage delays and denials on the part of MA plans.We appreciate your consideration of these issues. Our detailed comments are attached. Please contact me if you have questions or feel free to have a member of your team contact Shannon Wu, AHA’s director for payment policy, at (202) 626-2963 or&nbsp;<a href="mailto:swu@aha.org">swu@aha.org</a>.Sincerely,/s/Ashley Thompson Senior Vice President Public Policy Analysis and DevelopmentAttachment: Hospital Inpatient Prospective Payment System Tue, 10 Jun 2025 14:24:59 -0500 Letter/Comment AHA Comments on CMS TEAM Payment Model in FY 2026 Proposed Inpatient Payment Rule /2025-06-10-aha-comments-cms-team-payment-model-fy-2026-proposed-inpatient-payment-rule June 10, 2024The Honorable Mehmet Oz, M.D. Administrator Centers for Medicare &amp; Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201Submitted ElectronicallyRE: CMS-1833-P, Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2026 Rates; Requirements for Quality Programs; and Other Policy Changes, (Vol. 90, No. 82), April 30, 2025.Dear Administrator Oz,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&nbsp;comment on the Centers for Medicare &amp; Medicaid Services’ (CMS)&nbsp;proposed changes to the Transforming Episode Accountability Model (TEAM).&nbsp;We are submitting separate comments on the agency’s proposed changes to the inpatient and long-term care hospital prospective payment systems (PPSs).TEAM is a new, mandatory, episode-based payment model scheduled to begin on Jan. 1, 2026. The five-year program will require acute care hospitals in selected geographic areas to participate in five surgical episodes, including coronary artery bypass graft (CABG), lower extremity joint replacement (LEJR), major bowel procedure, surgical hip/femur fracture treatment (SHFFT) and spinal fusion. TEAM will hold acute care hospitals accountable for the quality and cost of all services provided during select surgical episodes, from the date of inpatient admission or outpatient procedure through 30 days post-discharge. Similar to other bundled payment models, TEAM participants will reconcile performance year spending against a target price to determine if a hospital is eligible for a reconciliation payment or repayment.Hospitals and health systems are eager for opportunities to participate in value-based payment arrangements and to drive innovation in the Medicare program. As such, the AHA and its members support innovative payment models that improve quality and lower costs. However, we continue to be concerned that TEAM does not meet these desired goals and may, in fact, hamper access to care by overburdening providers who do not have the infrastructure or population to be successful in this model, the way it is currently designed. Indeed, a majority of our&nbsp;<a href="/system/files/media/file/2024/06/aha-comments-on-cms-proposed-transforming-episode-accountability-model-team-letter-6-10-24.pdf">original concerns</a> about the model persist or have even been heightened by this rule. For example, TEAM has a very similar design to models such as Bundled Payments for Care Improvement (BPCI), BPCI Advanced (BPCI-A), and Comprehensive Care for Joint Replacement, none of which have&nbsp;either generated significant net savings or met statutory criteria for expansion, and yet this rule does not change the aspects of TEAM that could result in the same disappointing outcomes.&nbsp;In addition, in four out of the five TEAM episodes, over 71% of costs are incurred during the anchor hospitalization or outpatient procedure, for which reimbursement is already paid on a bundled basis, leaving few opportunities for savings by participants. Furthermore, for procedures such as spinal fusion and LEJR, over 40% of anchor costs are tied to supplies, equipment and implantable devices. We have advocated for exemptions of medical devices and equipment from tariffs, but should they go into effect, hospitals’ and health systems’ ability to impact these costs will decrease even further.<a href="#_ftn1" title="">[1]</a>,<a href="#_ftn2" title="">[2]</a>Our primary request continues to be that CMS make TEAM voluntary, as most recently highlighted in our&nbsp;<a href="/system/files/media/file/2025/05/aha-response-to-omb-deregulation-rfi-letter-5-12-2025.pdf">response</a> to the administration’s deregulation request for information. Mandatory participation is inappropriate given that many of the selected organizations are neither of an adequate size nor in a financial position to support the investments necessary to transition to mandatory bundled payment models. Requiring hospitals to take on large, diverse bundles would require more risk than many can manage, threatening their ability to maintain access to quality care in their communities.View the detailed letter below. Tue, 10 Jun 2025 13:34:25 -0500 Letter/Comment AHA Comments on CMS Inpatient Psychiatric Facility FY 2026 Proposed Payment Rule /2025-06-10-aha-comments-cms-inpatient-psychiatric-facility-fy-2026-proposed-payment-rule June 10, 2025The Honorable Mehmet Oz, M.D. Administrator Centers for Medicare &amp; Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201RE: Medicare Program; FY 2026 Inpatient Psychiatric Facilities Prospective Payment System – Rate Update (CMS-1831-P)Dear Administrator Oz:On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, and 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 comment on the Centers for Medicare &amp; Medicaid Services’ (CMS) inpatient psychiatric facility (IPF) prospective payment system (PPS) proposed rule for fiscal year (FY) 2026.Ensuring timely access to high-quality psychiatric care remains one of the most pressing challenges in our health care system. IPFs play a vital role in stabilizing individuals in crisis and supporting recovery. As communities across the country face rising demand for mental health services, it is essential that Medicare payment policies support the sustainability and availability of these specialized providers.To that end, we support several of the IPF PPS proposed rule provisions, including the proposed increases in the facility-level adjustments.&nbsp;We also appreciate the agency’s interest in deregulatory activities in the Medicare program and have submitted our comments through the request for information (RFI) website. We also support several aspects of CMS’ quality-related proposals, including its proposed removal of four measures from the quality reporting program.However, we continue to have strong concerns about the proposed payment updates. The proposed net payment update of 2.4% is simply inadequate given the unrelenting financial headwinds faced by hospitals and health systems. Without adequate and sustainable payment updates, IPFs will struggle to maintain access to essential psychiatric services, particularly in underserved communities where these services are already limited. We are particularly concerned with the inappropriately large productivity cut that is being proposed. We urge the agency to re-examine the magnitude of this adjustment and its impact on Medicare payments.View the detailed letter below. Tue, 10 Jun 2025 13:31:36 -0500 Letter/Comment AHA Comments on FTC Anticompetitive Deregulations RFI /lettercomment/2025-05-23-aha-comments-ftc-anticompetitive-deregulations-rfi <div class="container"><div class="row"><div class="col-md-8">May 23, 2025The Honorable Andrew N. Ferguson Chairman Federal Trade Commission 600 Pennsylvania Ave. NW Washington, DC 20580Re: Request for Public Comment Regarding Reducing Anti-Competitive Regulatory Barriers (Dkt. ID FTC-2025-0028-0001)Dear Chairman Ferguson:On behalf of the �� Association’s (AHA) nearly 5,000 member hospitals, health systems and other health care organizations, and 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 appreciate your invitation to submit comments identifying regulations that make health care markets less competitive.The AHA shares the Trump administration’s belief that the “ever-expanding morass of complicated Federal regulation imposes massive costs on the lives of millions of Americans, creates a substantial restraint on our economic growth and ability to build and innovate, and hampers our global competitiveness.”<a href="#fn1">1</a> And we share the Federal Trade Commission’s (FTC) belief that “[r]egulations that reduce competition, entrepreneurship, and innovation can hamper the American economy.”<a href="#fn2">2</a> We therefore welcome the opportunity to comment on the laws and regulations that make it harder for hospitals and health systems to compete fairly in the health care.As we submit these comments, we are mindful that this is, in many ways, well-trodden ground. In 2018, the first Trump administration issued a report entitled Reforming America’s Healthcare System Through Choice and Competition (2018 Report), which correctly observed that “many government laws, regulations, guidance, requirements and policies… resulted in healthcare markets that lack the benefits of vigorous competition. Increasing competition and innovation in the healthcare sector will reduce costs and increase quality of care—improving the lives of Americans.”<a href="#fn3">3</a> Seven years later, the AHA starts from that exact premise. Many of the issues identified in that 2018 Report remain or have worsened, and many new challenges have emerged. Then, as now, the U.S. health care system imposes a bewildering array of regulations on hospitals and health systems, adding significant administrative costs, disincentivizing pro-competitive arrangements, and promoting vertical consolidation of large commercial insurers to the detriment of patients and providers across the country.In this letter, we provide an overview of the key statutes and regulations that have impeded competition in the health care market and offer a series of recommendations to remedy these obstacles. We first outline the key areas of regulation that have permitted commercial insurers to limit market competition, narrow consumer choice and undermine access to health care for Americans — all while avoiding true accountability under the nation’s antitrust laws. We then describe other categories of regulations that limit the ability of hospitals and health systems to compete in the market, including those that impose undue administrative burdens, inhibit the expansion of telehealth, limit growth within the health care workforce and generally inflict large costs on the health care industry without corresponding benefits.<a href="#fn4">4</a><a href="/system/files/media/file/2025/05/AHA-Comments-on-FTC-Anticompetitive-Deregulations-RFI.pdf">Download the full letter.</a><hr><ol><li id="fn1">Executive Order 14192, Unleashing Prosperity Through Deregulation (Jan. 31, 2025).</li><li id="fn2">Press Release, Request for Public Comment Regarding Reducing Anti-Competitive Regulatory Barriers (April 13, 2025).</li><li id="fn3">U.S. Departments of Health and Human Services, Treasury, and Labor, Reforming America’s Healthcare System Through Choice and Competition (2018) at 16-17.</li><li id="fn4">AHA separately submitted comments incorporating many of these suggestions to HHS, CMS, and OMB as part of the parallel effort to reduce burdensome regulations. May 12, 2025, Letter from AHA to Secretary Kennedy, Administrator Oz, and Director Vought re Request for Information: Deregulation (FR Doc. 2025-06316) <a href="/lettercomment/2025-05-12-aha-response-omb-deregulation-rfi">/lettercomment/2025-05-12-aha-response-omb-deregulation-rfi</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/2025/05/AHA-Comments-on-FTC-Anticompetitive-Deregulations-RFI.pdf" target="_blank" title="Click here to download the AHA Comments on FTC Anticompetitive Deregulations RFI letter PDF.">Download the Letter PDF</a></div></div></div></div> Fri, 23 May 2025 11:50:55 -0500 Letter/Comment