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March 16, 2022
NHeLP Comments on Adding Race/Ethnicity to Medicare Part C & D Enrollment Form
Charly Gilfoil Comments
NHeLP submitted comments on the proposed 2023 Medicare Parts C & D Model Enrollment Form. For the first time, CMS will require plans to collect the race and ethnicity of individuals enrolling in Medicare Advantage or the Prescription Drug Program on the enrollment form. In our comments, we urge…
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January 27, 2022
NHeLP Comments on 2023 Notice of Benefit and Payment Parameters Proposed Rule
Mara Youdelman, Dania Douglas, Wayne Turner, David Machledt, Cathren Cohen, Héctor Hernández-Delgado, Abigail Coursolle, Alicia Emanuel, Elizabeth Edwards, and Charly Gilfoil Comments
NHeLP submitted comments on a vareity of topics addressed in the annual Notice of Benefit and Payment Parameters proposed rule. The rule governs marketplaces including HealthCare.gov and state based marketplaces.
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December 16, 2021
NHeLP Comments on HHS SUNSET Repeal Rule
Dania Douglas and Wayne Turner Comments
In the HHS SUNSET final rule, HHS sought 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 Even long-standing rules would be automatically rescinded unless they survive a complex process of assessment and review. If implemented, programs like Medicaid and the Children’s Health Insurance…
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September 15, 2021
Comments on NIST Proposal for Identifying & Managing Bias in AI
Elizabeth Edwards Comments
As awareness grows of the biases baked into artificial intelligence and other automated decision making, and the real world impacts of these systems on people, federal agencies like the National Institute of Standards and Technology are developing risk management frameworks for these systems. NHeLP submitted comments on NIST's recent…
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June 10, 2021
NHeLP AHRQ Comments
Elizabeth Edwards, David Machledt, Skyler Rosellini, and Liz McCaman Taylor Comments
In these comments, NHeLP responds to a request for information from AHRQ regarding the use of clinical algorithms that have the potential to introduce racial/ethnic bias into healthcare delivery. Using our long history of litigation and advocacy on issues that involve the use of automated decision-making systems, including algorithms,…
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February 16, 2021
Comments on Utah 1115 Primary Care Network Demonstration Waiver Amendment Request: In Vitro Fertilization and Genetic Testing for Qualified Conditions
Jennifer Lav and Catherine McKee Comments
In comments to the Department of Health and Human Services, the National Health Law Program asks HHS to reject Utah's proposal to restrict coverage of in vitro fertilization (IVF) services and preimplantation genetic diagnosis (PGD) for Medicaid-enrolled individuals who: (1) have been diagnosed by a physician as having a…
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NHeLP Comments on Adding Race/Ethnicity to Medicare Part C & D Enrollment Form

NHeLP Comments on 2023 Notice of Benefit and Payment Parameters Proposed Rule

NHeLP Comments on HHS SUNSET Repeal Rule

Comments on NIST Proposal for Identifying & Managing Bias in AI

NHeLP AHRQ Comments

Comments on Utah 1115 Primary Care Network Demonstration Waiver Amendment Request: In Vitro Fertilization and Genetic Testing for Qualified Conditions