Comment Letters

  • September 21, 2026 ABHW submits comments to CMS in response to the proposed rule on the indirect hold harmless threshold for Medicaid health care-related taxes.
  • September 14, 2026 ABHW CEO Debbie Witchey’s essay on Medicaid Managed Care.
  • September 14, 2026 ABHW submits comments on the CY2027 Medicare Physician Fee Schedule proposed rule.
  • July 31, 2026 ABHW respectfully request that the Centers for Medicare & Medicaid Services (CMS) consider these comments and recommendations in response to the Interim Final Rule with Comment Period (IFC or Rule) implementing the Medicaid community engagement requirements. 
  • July 13, 2026 ABHW encourages the IACC to support the development of high-quality and accessible ABA programs through the implementation of oversight and care planning protocols.
  • July 8, 2026 ABHW commends the reintroduction of the bipartisan Modernizing Opioid Treatment Access Act 2.0. 
  • July 6, 2026 ABHW encourages ONC to make behavioral health data interoperability an Agency priority by advancing modernization and certification pathways, national quality measure standards, and data-sharing compliance.
  • June 29, 2026 ABHW strongly supports the goal of improving provider directory accuracy. Accurate provider information is critical to helping Medicare Advantage (MA) beneficiaries identify available in-network providers and reducing frustration when seeking care.
  • June 15, 2026 ABHW is ready to support CMS and ONC in efforts to modernize health IT infrastructure, improve interoperability, and reduce unnecessary administrative burden.
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