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BIO Submits Comments Regarding HHS Notice of Benefit and Payment Parameters for 2016 Proposed Rule

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The Biotechnology Industry Organization (BIO) is pleased to submit the following comments regarding the Department of Health and Human Services&rsquo; (HHS&rsquo;s or the Department&rsquo;s) Proposed Rule entitled &ldquo;Notice of Benefit and Payment Parameters for 2016&rdquo; published on December 8, 2014 (the &ldquo;Proposed Rule&rdquo;).</p>

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 2016” published on December 8, 2014 (the “Proposed Rule”). While we acknowledge that HHS is working diligently to provide meaningful guidance to states and other stakeholders, we find that the Department’s reliance on a 30-day period provided to the public 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 health care industry, and public health. As established by Executive Order 12866, 60 days is the standard comment period for major rules. We urge HHS to follow the standard comment period in the future for rules continuing to implement the Affordable Care Act’s (ACA’s) requirements.