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Archives
- August 13, 2019
NHeLP comments on proposed rulemaking for Section 1557 – Nondiscrimination in Health and Health Education Programs or Activities
Read moreSection 1557 of the Affordable Care Act provides important protections against discrimination in health care programs and activities based on race, color, immigration status, language proficiency, sex, sex stereotypes, gender identity, age, or disability. However, the Trump administration is seeking to rollback regulations that help implement the law. In comments submitted…
- July 30, 2019
Comments on Proposed HUD Rule Affecting Mixed-status Immigrant Households
Read moreThe National Health Law Program submitted comments to the Department of Housing and Urban Development (HUD) in response to a proposed rule that would dramatically alter the agency’s eligibility requirements for federal housing assistance based on immigration status. If implemented, the rule would prohibit “mixed-status” families--families with one or…
- July 18, 2019
National Health Law Program Comments on D.C. 1115 Waiver Application
Read moreIn comments to the Department of Health and Human Services (HHS), The National Health Law Program urges HHS to reject the District of Columbia’s proposed Section 1115 Medicaid Behavioral Health Transformation Demonstration Program. As part of the demonstration, the District seeks to waive the Institutions for Mental Diseases (IMD)…
- June 21, 2019
Comments to OMB on Proposal to Change Poverty Measure
Read moreThe National Health Law Program submitted comments urging the Office of Management and Budget (OMB) to reject a proposal that would lower the federal poverty line. For the last several decades, OMB has used the Consumer Price Index-Urban inflation measure to update the Official Poverty Measure each year. Yet,…
- June 4, 2019
Public Comments on Medicaid’s Institutions for Mental Diseases (IMD) Exclusion
Read moreAs part of Support for Patients and Communities Act of 2018 (Support Act), Congress requested MACPAC submit a report on IMDs, and include any recommendations for changes to the exclusion. Any proposed changes to the IMD exclusion should be made with the utmost caution, and without undermining the purpose…
- April 8, 2019
National Health Law Program Comments on HHS Safe Harbor Rule for Outpatient Prescription Drugs
Read moreThe U.S. Department of Health and Human Services (HHS) proposed new regulations that would remove safe harbor protections for prescription drug rebates. Currently, rebates paid by manufacturers to Medicare Part D plans and Medicaid managed care organizations (MCOs), including pharmacy benefit managers (PBMs) are shielded from federal anti-kickback laws.…