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July 7, 2020
NHeLP Again Opposes Implementation of Double Billing Rule, Particularly During Pandemic
Fabiola De Liban Comments
As 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…
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March 25, 2020
Comments: Coordinating Care from Out-of-State Providers for Medicaid-Eligible Children with Medically Complex Conditions
Hannah Eichner Comments
The Centers for Medicare and Medicaid Services issued a Request for Information on access to care across state lines in Medicaid for children with medical complexity. NHeLP submitted comments which highlighted the importance of access to durable medical equipment while out-of-state, and emphasized the importance of adequate community-based services. NHeLP…
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March 19, 2020
Vasectomy Comments
Liz McCaman Taylor Comments
These comments were submitted in response to Notice 2018-12, in which the Internal Revenue Service (“IRS”) requested comments on the appropriate standards for preventive care under § 223(c)(2)(C) of the Internal Revenue Code of 1986 and "other issues related to the provision of preventive care” under a high deductible…
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February 18, 2020
Comments on USCIS Proposal to use SAVE to Collect Immigrant Sponsorship Info
Priscilla Huang and Sarah Grusin Comments
U.S. Citizenship and Immigraiton Services (USCIS) seeks to add optional questions for public benefit granting agencies to use the Systematic Alien Verification for Entitlements (SAVE) program to also provide USCIS with sponsorship data for deeming and reimbursement compliance. SAVE is used to verify immigration status for benefits eligibility purposes in programs such…
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February 18, 2020
Comments on HHS Proposed Rule on Religiously-Affiliated Providers
Wayne Turner Comments
HHS is attempting to roll back important protections for individuals seeking services from religiously-affiliated providers in a rulemaking it calls “Ensuring Equal Treatment of Faith-Based Providers.” The proposed rule would encourage religiously-affiliated providers to refuse to employ non-adherents and require that all employees and applicants for employment conform to…
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December 19, 2019
NHeLP Comments to Tennessee TennCare II Amendment 42 Waiver Application
Leonardo Cuello Comments
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NHeLP Again Opposes Implementation of Double Billing Rule, Particularly During Pandemic

Comments: Coordinating Care from Out-of-State Providers for Medicaid-Eligible Children with Medically Complex Conditions

Vasectomy Comments

Comments on USCIS Proposal to use SAVE to Collect Immigrant Sponsorship Info

Comments on HHS Proposed Rule on Religiously-Affiliated Providers

NHeLP Comments to Tennessee TennCare II Amendment 42 Waiver Application