Comment Letters
HFMA periodically issues comment letters to agencies such as the Centers for Medicare & Medicaid Services, the Internal Revenue Service, FASB and GASB, and other regulatory, legislative, and similar entities.
Our comment letters submitted since 2012 are listed below and organized by topic.
If you’re looking for a comment letter issued prior to 2012, please Contact Us.
- Principles & Practices Board Comments on GASB’s Proposed Statement on Leases (June 8, 2016)
- GASB’s Proposed Blending Requirements for Component Units (Oct. 28, 2015)
- FASB’s Proposal on NFP Financial Statement Presentation (Aug. 18, 2015)
- Modernizing and Clarifying the Physician Self-Referral Regulations Proposed Rule (Jan. 3, 2020)
- Anti-Kickback Statute and Civil Monetary Penalty Proposed Rule (Jan. 3, 2020)
- HRSA 340B Drug Pricing Program Omnibus Guidance (Oct. 28, 2015)
- HFMA Urges Support for the Stark Administrative Simplification Act [HR 3776] (Jan. 23, 2014)
- CMS’s Proposed Rule on Reporting and Returning of Overpayments (April 17, 2012)
- HFMA Comments on Federal Independent Dispute Resolution Operations, Proposed Rule (Dec. 6, 2023)
- HFMA Comments on Federal Independent Dispute Resolution Process Fees Proposed Rule (Oct. 26, 2023)
- HFMA Comments on Requirements Related to Surprise Billing, Part II Interim Final Rule (Dec. 8, 2021)
- HFMA’s Amicus Brief on Disclosure of ‘Negotiated Charges’ (July 27, 2020)
- HFMA Comments on the Transparency in Coverage Proposed Rule (Jan. 29, 2020)
- HFMA’s Response to CMS’s RFI on Hospital Chargemaster (Oct. 1, 2019)
- HFMA Comments on the Senate Transparency Initiative (March 22, 2018)
- Provider Relief Fund Coalition Letter to HHS on Ongoing COVID-19 Pressures (April, 19 2021)
- HFMA Comments on CARES Act Provider Relief Fund (PRF) Compliance Questions (Dec. 4, 2020)
- HFMA Comments on Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency (Dec. 3, 2020)
- HFMA Comments on CARES Act Provider Relief Fund Reporting Requirements (Oct. 26, 2020)
- HFMA Comments on Issues Related to COVID-19 Coding, AAP Loan Repayment, and Medicare CoP for Data Reporting (Sept. 25, 2020)
- HFMA Comments on CARES Act Provider Relief Fund Compliance Questions (Aug. 10, 2020)
- HFMA Comments on Acute Hospital Medicare Cost Report Issues Created by COVID-19 (Aug. 5)
- HFMA Comments on Measures to Ensure Safety Net Hospital Operational Sustainability (July 31)
- HFMA Comments on the Medicare Accelerated and Advanced Payment Programs (July 30)
- HFMA Comments on COVID-19 Interim Final Rules (July 13, 2020)
- HFMA Comments on Measures to Sustain Healthcare Providers During the COVID-19 Pandemic (April 15, 2020)
- HFMA Comments on Measures to Support Physician Practices During the COVID-19 Pandemic (April 13, 2020)
- HFMA Comments on Measures to Maintain Insurance Coverage During the COVID-19 Pandemic (April 7, 2020)
- HFMA Comments on Measures to Increase Provider Capacity and Reduce Administrative Burden During COVID-19 National Emergency (April 6, 2020)
- HFMA’s Response to the ONC’s RFI on Price Transparency (May 24, 2019)
- Transition to HIPAA Eligibility Transaction System (March 20, 2015)
- CMS Should Test the Readiness for ICD-10 Implementation (Jan. 10, 2014)
- CMS’s Proposed Rule to Delay ICD-10 (May 17, 2012)
- HFMA Comments on FY 2022 Hospital Inpatient Prospective Payment System Proposed Rule (June 29, 2021)
- FY 2021 IPPS Proposed Rule Comment Letter: Part 2 – DSH, Bad Debt, PAC Transfer and Stem Cell Acquisition Costs (July 13, 2021)
- FY 2021 IPPS Proposed Rule Comment Letter: Part 1 – Median Rate Reporting and Market-Based MS-DRG Rebasing (July 13, 2021)
- CMS’s FY2020 IPPS Proposed Rule (June 21, 2019)
- CMS’s FY2019 IPPS Proposed Rule (June 26, 2018)
- CMS’s FY2018 IPPS Proposed Rule (June 5, 2017)
- CMS’s FY2017 IPPS Proposed Rule (June 16, 2016)
- Medicare Program IPPS 0.2 Percent Reduction (Feb. 2, 2016)
- CMS’ FY2016 Hospital IPPS Proposed Rule (July 1, 2015)
- CMS’s Proposed Inpatient Hospital PPS Rule for FY15 (June 30, 2014)
- Medicare DSH Payment Reductions (March 13, 2014)
- CMS’ FY2014 IPPS Proposed Rule (June 24, 2013)
- Hospital Value-Based Purchasing (Oct. 17, 2012)
- CMS’s Hospital Readmissions Reduction Program (Jan. 31, 2012)
- HFMA Comments on CMS’s Proposed Changes to the Medicare Shared Savings Program (March 31, 2016)
- Proposed Rule on the Medicare Shared Savings Program (Feb. 6, 2015)
- HFMA Comments on Most Favored Nation (MFN) Model Interim Final Rule (Dec. 21, 2020)
- HFMA Comments on Comprehensive Care for Joint Replacement Model Three-Year Extension and Changes to Episode Definition and Pricing (April 24, 2020)
- HFMA Comments on CMS’s EPM IFR (April 19, 2017)
- HFMA Comments on CMS’s Advancing Care Coordination Through EPMs Proposal Rule (Oct. 3, 2016)
- CMS’s CCJR Payment Model Proposed Rule (Sept. 17, 2015)
- CMS Bundled Payments for Care Improvement (BPCI) Initiative (May 12, 2015)
- CMMI Bundled Payment for Care Improvement Initiative (May 21, 2012)
- HFMA’s Amicus Brief on Disclosure of ‘Negotiated Charges’ (July 27, 2020)
- HFMA Provides Recommendations to Medicare Red Tape Project (Aug. 2, 2017)
- CMS Discharge Planning Proposed Rule (Jan. 8, 2016)
- HFMA Comments on CY 2024 OPPS/ASC Proposed Rule (Sept. 26, 2023)
- HFMA Comments on Hospital OPPS: Proposed Remedy for the 340B-Acquired Drug Payment Policy for CYs 2018–2022 (Sept. 5, 2023)
- HFMA Comments on CY 2021 OPPS/ASC Proposed Rule (Oct. 5, 2020)
- HFMA’s Amicus Brief on Disclosure of ‘Negotiated Charges’ (July 27, 2020)
- HFMA’s Response to CMS’s RFI on Hospital Chargemaster (Oct. 1, 2019)
- HFMA Comments on the CY 2020 OPPS/ASC Proposed Rule (Oct. 1, 2019)
- HFMA Comments on the CY 2019 OPPS/ASC Proposed Rule (Sept. 28, 2018)
- HFMA Comments on the CY18 OPPS/ASC Proposed Rule (Sept. 11, 2017)
- CMS’s CY17 Hospital OPPS Proposed Rule (Sept. 6, 2016)
- CMS’s Medicare Program; Part B Drug Payment Model; Proposed Rule (May 9, 2016)
- CMS’ FY2016 Hospital OPPS Proposed Rule (Sept. 2, 2015)
- CMS’s 2015 Medicare OPPS Proposed Rule (Sept. 5, 2014)
- CMS’ FY14 Hospital Outpatient Prospective Payment Systems for Acute Care Hospitals (Sept. 6, 2013)
- Medicare Program IPPS 0.2 Percent Reduction (Feb. 2, 2016)
- Senate Finance Committee Chairmen’s Audit & Appeal Bill (June 22, 2015)
- Medicare Short Stay Payment Policy (April 21, 2015)
- Hospital Improvements for Payment Act of 2014 Discussion Draft (March 3, 2015)
- Delay of RAC Appeals Assigned to Administrative Law Judges (March 25, 2014)
- HFMA Supports the Two-Midnight Rule Delay Act (HR 3698) (Jan. 30, 2014)
- Medicare Recovery Audit Contractor Program (Oct. 21, 2013)
- Medicare Part B Inpatient Hospital Billing and the RAC Program (May 20, 2013)
- HFMA Comments on CY 2021 Physician Fee Schedule Proposed Rule (Oct. 6, 2020)
- HFMA Comments on the CY 2019 Physician Fee Schedule Proposed Rule (Sept. 11, 2018)
- HFMA Comments on the CY18 Physician Fee Schedule Proposed Rule (Sept. 6, 2017)
- HFMA Comments on the CY18 Updates to the Quality Payment Program Proposed Rule (Aug. 21, 2017)
- HFMA Comments on CMS’s CY17 Medicare Physician Fee Schedule Proposed Rule (Aug. 26, 2016)
- CMS’s MACRA Proposed Rule (June 27, 2016)