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December 3, 2020
NHeLP Comments on HHS Regulations Rule (aka SUNSET Rule)
Wayne Turner and Dania Douglas Comments
In the Regulations Rule, HHS seeks to retroactively impose a mandatory expiration date on an estimated 18,000 duly promulgated regulations. Even long-standing rules would be automatically rescinded unless they survive a complex process of assessment and review. Programs like Medicaid and the Children's Health Insurance Program (CHIP) could be…
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November 19, 2020
California Policy Needs During COVID and Beyond: Due Process
Skyler Rosellini Issue Brief
Medi-Cal is a lifeline for Californians during the COVID-19 public health emergency (PHE). Among the many crucial benefits of Medi-Cal, beneficiaries have strong due process protections including the right to written notices, an appeal of denials, and a hearing. These protections ensure that beneficiaries have meaningful rights to challenge…
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October 13, 2020
NHeLP response to HHS Request for Information on Guidance Documents
Wayne Turner Letter
HHS posted an undated Request for Information (RFI) on its website asking for input on which guidance documents should undergo notice and comment. In this response, NHeLP object to HHSposting the RFI while a formal rulemaking on the same issue is pending. See NHeLP Comments on HHS Proposed Rule…
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September 14, 2020
NHeLP comments on HHS Proposed Rule on Guidance
Wayne Turner and Dania Douglas Comments
Guidance documents are a valuable tool that allows agencies to clarify policy issues and explain ambiguities raised by the laws and rules they are tasked with implementing. Programs like Medicaid and the implementation of the Affordable Care Act depend heavily on guidance documents to clarify coverage requirements and the…
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July 20, 2020
NHeLP comments on Medicaid Prescrption Drug Rebate Program and Value- based Purchasing Proposed Rulemaking
Wayne Turner, Liz McCaman Taylor, Madeline Morcelle, and Cathren Cohen Comments
In a proposed rule, CMS seeks to expand value-based purchasing arrangements for prescription drugs in commercial plans and the Medicaid program. However, the proposed changes offer a cost-containment strategy with no safeguards to ensure that Medicaid enrollees can continue to access needed outpatient prescription drugs. NHeLP comments warn against“cost…
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June 19, 2020
HHS Eliminates or Weakens Regulatory Protections Against Discrimination in Health Care
Wayne Turner, Mara Youdelman, and Madeline Morcelle Issue Brief, Fact Sheet
As part of its ongoing attacks on health care and civil rights, the Trump administration recently finalized drastic changes to regulations implementing Section 1557, the Affordable Care Act’s nondiscrimination provision. Section 1557 provides important protections against discrimination on the basis of race, color, national origin (including language access), sex,…
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NHeLP Comments on HHS Regulations Rule (aka SUNSET Rule)

California Policy Needs During COVID and Beyond: Due Process

NHeLP response to HHS Request for Information on Guidance Documents

NHeLP comments on HHS Proposed Rule on Guidance

NHeLP comments on Medicaid Prescrption Drug Rebate Program and Value- based Purchasing Proposed Rulemaking

HHS Eliminates or Weakens Regulatory Protections Against Discrimination in Health Care