Today, FAH submitted comprehensive comments to the US Department of Health and Human Services (HHS) in response to its Request for Information (RFI): Ensuring Lawful Regulation and Unleashing Innovation To Make America Healthy Again, which seeks public input on how to dramatically deregulate across all areas of HHS.  FAH comments urged wide-ranging deregulatory initiatives, including those previously submitted to CMS in June, along with additional recommendations.  Key recommendations include, among others:

• Oversight and compliance enforcement for Medicare Advantage plans.
• Reject site-neutral cuts to Medicare.
• Eliminate the inpatient rehabilitation facility Review Choice Demonstration.
• Enforce the No Surprises Act Independent Dispute Resolution process.
• Rescind interpretive guidance implying nurse staff ratio requirements.
• Remove premature, low-value, and/or outdated hospital quality measures, as well as mandatory reporting for electronic clinical quality measures (eCQMs), along with requiring pre-deployment testing of hospital quality measures and reporting structures.
• Right-size CMMI models and halt mandatory approaches.
• Phase out or simplify the Promoting Interoperability Program.
• Discontinue further development of the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs), while continuing with the Traditional MIPS program for measuring clinician performance.
• Develop a more centralized model for public health reporting.
• Remove CoP requirements for respiratory illness reporting and maternal health, while revising or updating CoPs for emergency services readiness and life safety codes.
• Repeal provider disincentives for information blocking regulations.
• Withdraw cybersecurity proposed regulations.
• Expand eligibility for the 340B drug pricing program to tax-paying hospitals.

Read the full comment letter here.