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- September 17, 2020
NHeLP comments on Approved Drug Products with Therapeutic Equivalence Evaluations (the “Orange Book”)
Read moreThe Orange Book is an important and informative drug resource for a range of stakeholders. In a request for comments, FDA seeks feedback on the types of people or entitles using the Orange Book, additional information and features to incorporate into the Orange Book, and therapeutic equivalence information. NHeLP…
- September 17, 2020
Utah 1115 IMD Demonstration Request Comment
Read moreUtah has applied for an 1115 demonstration waiving the IMD exclusion for people with serious mental illnesses. NHeLP submitted a comment opposing the demonstration request.
- September 14, 2020
NHeLP comments on HHS Proposed Rule on Guidance
Read moreGuidance 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…
- July 24, 2020
Comments: Oklahoma Section 1115 Application.
Read moreIn comments to the Department of Health and Human Services, the National Health Law Program asks HHS to reject Oklahoma's proposed project, which would impose a number of unlawful conditions on coverage and access to care. Oklahoma also requested permission to shift to per capita cap funding for the…
- July 20, 2020
NHeLP comments on Medicaid Prescrption Drug Rebate Program and Value- based Purchasing Proposed Rulemaking
Read moreIn 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…
- July 7, 2020
NHeLP Again Opposes Implementation of Double Billing Rule, Particularly During Pandemic
Read moreAs conveyed in our comments to the proposed rule, the National Health Law Program strongly opposes the implementation of the “Double Billing” rule promulgated on December 27, 2019 because it threatens to undermine access to quality health care, including essential reproductive health services. We implore the administration, states, and…
