BIO Submits Comments Re: HHS Notice of Benefit and Payment Parameters for 2017
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Sylvia Mathews Burwell</div>
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Secretary</div>
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U.S. Department of Health and Human Services</div>
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200 Independence Avenue, S.W.</div>
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Washington, D.C. 20201</div>
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Andrew M. Slavitt</div>
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Acting Administrator</div>
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Centers for Medicare and Medicaid Services</div>
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7500 Security Boulevard</div>
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Baltimore, M.D. 21244</div>
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BY ELECTRONIC DELIVERY</div>
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Re: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017 [CMS-9937-P]</div>
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Sylvia Mathews Burwell
Secretary
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
Andrew M. Slavitt
Acting Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, M.D. 21244
BY ELECTRONIC DELIVERY
Re: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017 [CMS-9937-P]
Dear Secretary Burwell and Acting Administrator Slavitt:
The Biotechnology Industry Organization (BIO) is pleased to submit the following comments regarding the Department of Health and Human Services’ (HHS’s or the Department’s) Proposed Rule entitled “Notice of Benefit and Payment Parameters for 2017” published in the Federal Register on November 20, 2015 (the “Proposed Rule”).1 While we acknowledge that HHS is working diligently to provide meaningful guidance to states and other stakeholders, we find that the Department’s continued reliance on a 30-day public comment period does not allow for thorough consideration by the public of all the proposals contained in this rule. The proposals contained in this rule have significant and far-reaching implications for patients, the healthcare industry, and public health. As established by Executive Order 12,866, 60 days is the standard comment period for major rules.2 We continue to urge HHS to follow the standard comment period in the future for rules implementing the Affordable Care Act’s (ACA’s) requirements, particularly those which contain new or significantly modified policy proposals.
