The Asian & Pacific Islander American Health Forum (APIAHF) submitted this comment letter in response to the Department of Health and Human Services (HHS) proposed rule, “Securing Updated and Necessary Statutory Evaluations Timely.”
The proposed rule would retroactively impose an expiration provision on most HHS regulations, and establish “assessment” and “review” procedures to determine which, if any, regulations should be retained or revised. The Regulations Rule is an ill-conceived proposal that would create tremendous administrative burden for HHS and would wreak havoc across a broad swath of Department programs and regulated entities from Medicaid and Medicare to Food and Drug Administration (FDA) and the Centers for Disease Control and Prevention (CDC). We also strongly object to the truncated 30-day comment period which is insufficient for a rule of this broad scope with potentially harmful effects. Due to the administrative burdens imposed by the proposed rule, it would divert critical resources from HHS responding to the nation’s health, particularly during this COVID-19 national emergency. As such, we urge HHS to immediately withdraw this proposed rule.