NACHC monitors and comments on regulations through a process known as rulemaking, which provides opportunities for the public to submit written comments in response to proposed regulatory changes. While any individual member can comment on a proposed rule, there is power in numbers, so our role as an association representing a large number of constituents can carry a lot of weight.
Furthermore, we create customizable template comment letters to enable more organizations to submit their own unique comments. This page will provide updates on opportunities to engage and comment on any rules affecting health centers.
2023 Comment Letters
- Notice of Benefit and Payment Parameters 2024 Comment Letter
- CMS Essential Health Benefits Request for Information
- 340B Administrative Dispute Resolution Comment Letter
- Prior Authorization Comment Letter
- DEA Proposed Rule on Buprenorphine
- DEA Proposed Rule on Telemedicine
- Medicaid Fee-for-Service Access Comment Letter
- Medicaid Managed Care, Quality, and Finance Comment Letter
- Medicaid Drug Rebate Program Comment Letter
2023 Comment Templates
NACHC Comment Letter Template: Medicare Physician Fee Schedule (September 2023) Due Monday, September 11th by 5PM ET. Use our customizable template to respond to the CY24 Medicare Physician Fee Schedule proposed rule. This is an annual regulation that proposes changes to the Medicare program. Submit your comments.
This letter includes regulatory policy asks such as:
- Supporting CMS’ proposal to allow FQHCs to bill for Remote Patient Monitoring, Community Health Integration, and Principal Illness Navigation
- Advocating to ensure FQHCs can bill for an SDOH Risk Assessment, as a stand-alone and as part of an Annual Wellness Visit
- Supporting adding Licensed Marriage & Family Therapists and Licensed Mental Health Counselors to the Medicare billable providers list for FQHCs
- And more!