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Federal Issues

AzHHA is intimately involved with federal issues impacting hospitals, the delivery of healthcare, and the health of patients and communities.

Through our partnership with the American Hospital Association, AzHHA continually monitors policies considered by Congress and the federal administration that could have an impact on the delivery of healthcare services provided by hospitals. 

AzHHA also keeps abreast of innovation affecting the healthcare industry, healthcare policies advocated by national stakeholders and litigation that could impact the delivery of care. Once reviewed, AzHHA carefully selects which issues to support or oppose.

Below are letters AzHHA has submitted to the federal government and Arizona's Congressional Delegation on important federal issues affecting healthcare in Arizona, as well as briefs AzHHA has joined that have been filed in courts of federal jurisdiction.


Comment Letters

Comment Letter to OSHA on ETS Interim Final Rule - April 2022

Comment Letter to CMS on FY2022 IPPS Proposed Rule - June 2021

Comment Letter to CMS on FFY2022 IRF PPS - June 2021

Comment Letters on Medicaid Fiscal Accountability Regulation - 2020 various dates

Comment Letters on COVID-19 relief funding - 2020 various dates

Comment Letter to CMS on OPPS Proposed Rules for FFY2021 - October 2020

Comment Letter to CMS on IPPS Proposed Rules for FFY2021 - July 2020

Comment Letter to CMS on IRF Proposed Rules for FFY2021 - June 2020

Comment Letter to CMS on Transparency in Coverage (CMS-9915-P) - January 2020

Comment Letter to U.S. Department of Homeland Security on Public Charge - December 2018

Comment Letter to CMS on 2019 Physician Fee Schedule - September 10, 2018

Comment Letter to CMS on 2018 Inpatient Rehabilitation Facility PPS Proposed Rule - June 2017 

Comment Letter to AHCCCS on IMD Waiver - March 2017

Comment Letter to HRSA on 340B - Arbitration Rule - October 2016

Comment Letter to CMS on MIPS - June 2016

Comment Letter on CMS 2015 Discharge Planning Proposed Rules - January 2016

Comment Letter to HRSA on 340B - Mega Guidance - October 2015

Comment Letter to CMS on Medicaid MCO - July 2015


Court Filings

340B program Amicus Brief - February 2021

Site neutral Amicus Brief - February 2021

ACA litigation Amicus Brief - May 2020


Additional Documents

Affordable Care Act Litigation Update & Analysis - January 2021

February 2015 - Medicare Cut Break Down - February 2015 

2014 AzHHA Congressional Briefing Book - April 2014