Modernizing Regulatory Review: Health Groups Comment Letter on Proposed Changes to Circular A-4

Executive Summary

In April of 2023, the Office of Management and Budget (OMB) issued a proposed series of changes to Circular A-4, a 2003 guidance document that helps instruct federal agencies on how to assess the impacts of regulatory analysis. The proposals bring modern economic analysis to this review, better account for the experiences of low-income and underserved populations and will promote more equitable access to health coverage and health care. This following comments were signed onto by a diverse cross-section of over 40 groups concerned about the regulatory process and its impact on access to health coverage and health care.

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