/ en Sat, 14 Jun 2025 13:20:43 -0500 Fri, 23 May 25 11:50:55 -0500 /lettercomment/2025-05-23-aha-comments-ftc-anticompetitive-deregulations-rfi <div class="container"><div class="row"><div class="col-md-8"><p>May 23, 2025</p><p>The Honorable Andrew N. Ferguson<br>Chairman<br>Federal Trade Commission<br>600 Pennsylvania Ave. NW<br>Washington, DC 20580</p><p><em><strong>Re: Request for Public Comment Regarding Reducing Anti-Competitive Regulatory Barriers (Dkt. ID FTC-2025-0028-0001)</strong></em></p><p>Dear Chairman Ferguson:</p><p>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.</p><p>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"><sup>1</sup></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"><sup>2</sup></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.</p><p>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 <em>Reforming America’s Healthcare System Through Choice and Competition</em> (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"><sup>3</sup></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.</p><p>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"><sup>4</sup></a></p><p><a href="/system/files/media/file/2025/05/AHA-Comments-on-FTC-Anticompetitive-Deregulations-RFI.pdf"><span><em><strong>Download the full letter.</strong></em></span></a></p><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 Regulations and Regulatory Advocacy /news/headline/2025-05-23-aha-responds-doj-ftc-anticompetitive-regulation-rfis <p>AHA May 23 submitted recommendations to the <a href="/system/files/media/file/2025/05/AHA-Comments-on-DOJ-Anticompetitive-Deregulations-RFI.pdf">Department of Justice</a> and <a href="/system/files/media/file/2025/05/AHA-Comments-on-FTC-Anticompetitive-Deregulations-RFI.pdf">Federal Trade Commission</a> in response to the agencies’ requests for information on unnecessary or burdensome anticompetitive regulations. “[T]he 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,” AHA Deputy General Counsel Julie Rapoport Schenker wrote in the letters to the agencies. The AHA’s recommendations included addressing regulations that foster anticompetitive conduct by insurers and limit the ability of hospitals and health systems to thrive in a competitive free market, among others. <br><br>The RFIs follow a similar request from the Office of Management and Budget regarding deregulation, to which the AHA <a href="/lettercomment/2025-05-12-aha-response-omb-deregulation-rfi">responded</a> May 13. </p> Fri, 23 May 2025 10:44:03 -0500 Regulations and Regulatory Advocacy /lettercomment/2025-05-23-aha-comments-doj-anticompetitive-deregulations-rfi <div class="container"><div class="row"><div class="col-md-8"><p>May 23, 2025</p><p>The Honorable Abigail Slater<br>Assistant Attorney General<br>Anticompetitive Regulations Task Force<br>Antitrust Division<br>U.S. Department of Justice<br>950 Pennsylvania Ave. NW<br>Washington, DC 20530</p><p><em><strong>Re: Anticompetitive Regulations Task Force Press Release (Dkt. ID ATR-2025-0001-0002)</strong></em></p><p>Dear Assistant Attorney General Slater and Task Force Members:</p><p>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.</p><p>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"><sup>1</sup></a> And we share the Department of Justice’s (DOJ) belief that “unnecessary anticompetitive regulations put affordable healthcare out of reach for millions of American families.”<a href="#fn2"><sup>2</sup></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 marketplace — which DOJ rightly identifies as one of the “markets that ha[s] the greatest impact on American households.”</p><p>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"><sup>3</sup></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.</p><p>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"><sup>4</sup></a></p><p><a href="/system/files/media/file/2025/05/AHA-Comments-on-DOJ-Anticompetitive-Deregulations-RFI.pdf"><span><em><strong>Download the full letter.</strong></em></span></a></p><hr><ol><li id="fn1">Executive Order 14192, Unleashing Prosperity Through Deregulation (Jan. 31, 2025).</li><li id="fn2">Press Release, Justice Department Launches Anticompetitive Regulations Task Force (March 27, 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-DOJ-Anticompetitive-Deregulations-RFI.pdf" target="_blank" title="Click here to download the AHA Comments on DOJ Anticompetitive Deregulations RFI letter PDF.">Download the Letter PDF</a></div></div></div></div> Fri, 23 May 2025 10:10:08 -0500 Regulations and Regulatory Advocacy /news/headline/2025-05-13-public-comment-period-opens-deregulation-rfi-hhs <p>The Department of Health and Human Services May 13 <a href="https://www.hhs.gov/press-room/fda-10-to-1-deregulatory-plan-to-lower-costs-empower-patients.html" target="_blank">announced</a> a 60-day public comment period opened for stakeholders regarding its <a href="https://www.federalregister.gov/public-inspection/2025-08384/request-for-information-ensuring-lawful-regulation-and-unleashing-innovation-to-make-american" target="_blank">request for information</a> to remove outdated or unnecessary regulations. The request stems from an <a href="https://www.whitehouse.gov/presidential-actions/2025/01/unleashing-prosperity-through-deregulation/" target="_blank">executive order</a> issued in January requiring HHS to implement a “10-to-1” rule, eliminating at least 10 existing regulations for every new regulation introduced. Comments on the RFI can be submitted at <a href="https://www.regulations.gov/deregulation" target="_blank">regulations.gov/deregulation</a>.</p><p>The RFI follows a similar request from the Office of Management and Budget regarding <a href="https://www.federalregister.gov/documents/2025/04/11/2025-06316/request-for-information-deregulation" target="_blank">deregulation</a>, to which the AHA <a href="/lettercomment/2025-05-12-aha-response-omb-deregulation-rfi" target="_blank">responded</a> May 12. The AHA’s recommendations fell under four categories: billing, payment and other administrative requirements; quality and patient safety; telehealth; and workforce. The fiscal year 2026 inpatient prospective payment system, skilled nursing facility, inpatient rehabilitation facility, inpatient psychiatric facility and long-term care hospital payment rules also have similar regulatory relief requests for information that are due June 10.</p> Tue, 13 May 2025 17:14:55 -0500 Regulations and Regulatory Advocacy <div class="container"><div class="row"><div class="col-md-8"><p>Directs the Commissioner of the Food and Drug Administration to review and eliminate any duplicative or unnecessary requirements in regulations and guidance pertaining to the development of domestic pharmaceutical manufacturing within 180 days. Further directs the commissioner to streamline and accelerate the development of domestic pharmaceutical manufacturing, and requires the commissioner to review regulations and guidance regarding the inspection and approval of manufacturing capabilities and emerging technologies that enable the manufacturing of pharmaceutical products and ingredients. Directs the commissioner to review the current risk-based approach to prior approval of licensure inspections and further directs the commissioner to undertake measures to improve enforcement of data reporting and to issue guidance on production, compliance, and related issues. Requires the commissioner to develop and advance improvements to the inspection regime within 90 days and make public disclosures regarding the annual number of inspections conducted by the FDA on foreign facilities.</p><p>Directs the Administrator of the Environmental Protection Agency to update regulations and guidance with respect to the inspection and approval of pharmaceutical manufacturing capacity and eliminate duplicative or unnecessary requirements within 180 days. Establishes the EPA as the lead agency for the permitting of pharmaceutical manufacturing facilities that require preparation of an Environmental Impact Statement and directs the EPA to work with the Office of Management and Budget and other agencies to expedite the review and approval of relevant permits. Further directs the Secretary of the Army, within 180 days, to review permits issued pursuant to certain environmental laws and determine whether additional permits are necessary to facilitate the efficient permitting of pharmaceutical manufacturing facilities.</p></div></div></div> Mon, 05 May 2025 08:06:32 -0500 Regulations and Regulatory Advocacy /news/headline/2025-04-15-cms-update-spa-template-medication-assisted-treatment-benefit <p>The Centers for Medicare & Medicaid Services today released a <a href="https://www.federalregister.gov/public-inspection/2025-06400/agency-information-collection-activities-proposals-submissions-and-approvals-medicaid-and-childrens" title="CMS notice">notice</a> seeking public comment on the collection of information request regarding the State Plan Amendment template for medication-assisted treatment. SPA templates are provided by CMS to assist states with Medicaid application submissions as well as reducing administrative burden and increasing efficiency. States are required to cover MATs for opioid use disorder under their state Medicaid programs. CMS said it is planning to update the SPA template for MAT to align with statutory updates. The comment period will be open for 14 days following publication in the April 16 Federal Register.</p> Tue, 15 Apr 2025 14:47:55 -0500 Regulations and Regulatory Advocacy /news/headline/2025-04-10-trump-administration-issues-executive-orders-reducing-anti-competitive-barriers-repealing-unlawful <p>The Trump administration yesterday released executive orders on reducing anti-competitive regulatory <a href="https://www.whitehouse.gov/presidential-actions/2025/04/reducing-anti-competitive-regulatory-barriers/" title="EO on barriers">barriers</a> and repealing certain <a href="https://www.whitehouse.gov/presidential-actions/2025/04/directing-the-repeal-of-unlawful-regulations/" title="EC on regs">regulations</a> deemed unlawful.  </p><p>  </p><p>The order on reducing anti-competitive barriers directs federal agencies to review all regulations subject to their rulemaking authority and identify those that create de facto or de jure monopolies, create barriers to entry for new market participants, create or facilitate licensure or accreditation requirements that unduly limit competition, or otherwise impose anti-competitive restraints or distortions in the market.   </p><p>  </p><p>The order on repealing unlawful regulations is linked to a Feb. 25 <a href="https://www.federalregister.gov/documents/2025/02/25/2025-03138/ensuring-lawful-governance-and-implementing-the-presidents-department-of-government-efficiency" title="Feb 5 EO">executive order</a> that directed agencies within 60 days to identify unlawful and potentially unlawful regulations to be repealed. The new order instructs agencies to take steps to immediately repeal regulations and provide justification within 30 days for any identified as unlawful but have not been targeted for repeal, explaining the basis for the decision not to repeal.</p> Thu, 10 Apr 2025 15:26:14 -0500 Regulations and Regulatory Advocacy <div class="container"><div class="row"><div class="col-md-8"><p>The Trump administration April 9 released a series of executive orders (EOs) and took other administrative actions aimed at reducing regulatory burden.</p><p>The Office of Management and Budget April 9 issued a <a href="https://www.federalregister.gov/public-inspection/2025-06316/request-for-information-deregulation" target="_blank" title="Federal Register: Request for Information: Deregulation">request for information (RFI)</a> seeking public comment on regulations that should be rescinded as unnecessary, unlawful, unduly burdensome or unsound. According to the RFI, recommendations should focus on regulations that are inconsistent with statutory text or the Constitution, entail costs that exceed benefits, are outdated or unnecessary, or are otherwise burdening businesses in unforeseen ways. Comments are due within 30 days of publication in the Federal Register.</p><p>Relatedly, the White House issued two EOs, <a href="https://www.whitehouse.gov/presidential-actions/2025/04/directing-the-repeal-of-unlawful-regulations/" target="_blank" title="The White House: Directing the Repeal of Unlawful Regulations">“Directing the Repeal of Unlawful Regulations”</a> and <a href="https://www.whitehouse.gov/presidential-actions/2025/04/reducing-anti-competitive-regulatory-barriers/" target="_blank" title="The White House: Reducing Anti-competitive Regulatory Barriers">“Reducing Anti-Competitive Regulatory Barriers.”</a></p><h2>Directing the Repeal of Unlawful Regulations</h2><p>This EO is linked to the Feb. 25 EO 14219, <a href="https://www.federalregister.gov/documents/2025/02/25/2025-03138/ensuring-lawful-governance-and-implementing-the-presidents-department-of-government-efficiency" target="_blank" title="Federal Register: Ensuring Lawful Governance and Implementing the President's " department of government deregulatory>“Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative.”</a> EO 14219 directed agencies to identify, within 60 days (approximately April 20), categories of unlawful and potentially unlawful regulations to be repealed. The related April 9 EO tasks agencies with immediately taking steps to repeal regulations after the 60-day period has ended, prioritizing those regulations that implicate several Supreme Court rulings. Additionally, it requires agencies to provide justification within 30 days for any regulations that were identified as unlawful but have not been targeted for repeal, explaining the basis for the decision not to repeal.</p><h2>Reducing Anti-Competitive Regulatory Barriers</h2><p>This EO directs federal agencies to review all regulations subject to their rulemaking authority and identify those regulations that create de facto or de jure monopolies, create barriers to entry for new market participants, create or facilitate licensure or accreditation requirements that unduly limit competition, or otherwise impose anti-competitive restraints or distortions in the market. Agencies must submit recommendations to the Federal Trade Commission (FTC) and the Attorney General on whether anti-competitive regulations should be rescinded or modified within 70 days of the order (approximately June 18). Additionally, the EO directs the FTC to issue, within 10 days of the order, an RFI seeking public comment on anti-competitive regulations.</p><p>Additional information will be forthcoming as agencies provide supporting guidance or notices.</p><h2>Additional Information on Executive Actions</h2><p>The Trump administration has issued many executive orders and taken other administrative actions. The AHA has compiled a <a href="/system/files/media/file/2025/01/2025-New-Executive-Orders-20250127.pdf">tracker of the actions the administration has taken</a> that may be of interest to hospitals and health systems. The tracker will be updated regularly as new actions are taken.</p><h2>Further Questions</h2><p>If you have further questions, please contact the AHA at <a href="tel:1-800-424-4301">800-424-4301</a>.</p></div><div class="col-md-4"><p><a href="/system/files/media/file/2025/04/Member-Advisory-Trump-Administration-Issues-Additional-Deregulation-Orders-and-Notices.pdf" target="_blank" title="Click here to download the Member Advisory: Trump Administration Issues Additional Deregulation Orders and Notices PDF."><img src="/sites/default/files/inline-images/Page-1-Member-Advisory-Trump-Administration-Issues-Additional-Deregulation-Orders-and-Notices.png" data-entity-uuid="31a05d9f-f2f8-46cb-9473-74ff7873b661" data-entity-type="file" alt="Member Advisory: Trump Administration Issues Additional Deregulation Orders and Notices page 1." width="695" height="900"></a></p></div></div></div> Thu, 10 Apr 2025 14:32:06 -0500 Regulations and Regulatory Advocacy /news/headline/2025-04-09-omb-seeks-input-rules-potential-deregulation <p>The Office of Management and Budget April 9 released a <a href="https://www.federalregister.gov/public-inspection/2025-06316/request-for-information-deregulation" target="_blank">notice</a> seeking public input on rules to potentially be rescinded, requesting detailed reasons for their rescission. Comments must be received by OMB no later than 30 days after publication of the notice in the Federal Register. The notice will be published April 11. Comments can be submitted at <a href="http://www.regulations.gov">www.regulations.gov</a>.</p> Wed, 09 Apr 2025 15:30:01 -0500 Regulations and Regulatory Advocacy <div class="container"><div class="row"><div class="col-md-8"><p>The Department of Health and Human Services (HHS) Feb. 28 issued a notice in the <a href="https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Femail.advocacy.aha.org%2FNzEwLVpMTC02NTEAAAGZAg2wgva7m2GO2kNGb3Z_SaO9EW7IYPqYlaUscce4T87I0ccBt3kysnNnETNrJFMJkeYNllM%3D&data=05%7C02%7Cdsamuels%40aha.org%7C878c3e4687c74e688bd808dd5b645fc9%7Cb9119340beb74e5e84b23cc18f7b36a6%7C0%7C0%7C638767208853979537%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=ejtWcXCU%2B%2Fs06y2t9xkE9cffKJzyVx0%2Fg28PKBCSiho%3D&reserved=0" target="_blank">Federal Register</a> rescinding its 1971 policy known as the “Richardson Waiver.” The Administrative Procedure Act (APA) generally requires federal agencies to give interested parties an opportunity to participate in rulemaking through the submission of written comments. However, the APA exempts from these notice-and-comment requirements “matter(s) relating to agency management or personnel or to public property, loans, grants, benefits, or contracts.” Under the 1971 Richardson Waiver, HHS chose to require the APA’s notice-and-comment rulemaking procedures for these types of matters, even though they are not required to do so under law.</p><p><strong>The AHA has received several questions from its members about Friday’s rescission of the Richardson Waiver. To help hospitals and health systems understand the implications of this announcement, the AHA is sharing a </strong><a href="https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Femail.advocacy.aha.org%2FNzEwLVpMTC02NTEAAAGZAg2wgpoGkU4z0h0FKPveTmvU-LfI0DxmkMT6q9WRG09REi37fZZTArgdVlSntGrKQjEzUxY%3D&data=05%7C02%7Cdsamuels%40aha.org%7C878c3e4687c74e688bd808dd5b645fc9%7Cb9119340beb74e5e84b23cc18f7b36a6%7C0%7C0%7C638767208853992089%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=ZoyZBJIHVtGX%2FNECt5pRvshRCrCohbnXCYSKsWSpm94%3D&reserved=0" target="_blank"><strong>memo</strong></a><strong> that it commissioned from outside counsel.</strong></p><p><strong>QUESTIONS</strong></p><p>If you have further questions, please contact AHA General Counsel Chad Golder at <a href="https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Femail.advocacy.aha.org%2FNzEwLVpMTC02NTEAAAGZAg2wgoDChqOjakp2rvMgEmCEbIQbe2yPfQw2FN58hFw-B5ngId07TwLZH9XmPohDWBxYOzg%3D&data=05%7C02%7Cdsamuels%40aha.org%7C878c3e4687c74e688bd808dd5b645fc9%7Cb9119340beb74e5e84b23cc18f7b36a6%7C0%7C0%7C638767208854003810%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=IbhJ3ePkj%2BWl9U0z9B%2Bh%2F%2BDImNUShHY9h3npjHipACI%3D&reserved=0" target="_blank">cgolder@aha.org</a>.</p></div><div class="col-md-4"><a href="/system/files/media/file/2025/03/guidance-for-hospitals-hhs-rescission-of-richardson-waiver-affecting-public-comment-advisory-3-5-25.pdf"><img src="/sites/default/files/inline-images/cover-guidance-for-hospitals-hhs-rescission-of-richardson-waiver-affecting-public-comment-advisory-3-5-25.png" data-entity-uuid="dad1a0b6-c24f-4306-a737-40971f4a9770" data-entity-type="file" alt="Cover image Member Advisory" width="679" height="878"></a></div></div></div> Tue, 04 Mar 2025 11:14:04 -0600 Regulations and Regulatory Advocacy