Public Comment Letters on Federal Regulations and Policies
Public Comment Letters on Federal Regulations and Policies
Public comment letter in response to the Centers for Disease Control and Prevention’s Notice announcing a meeting of the Advisory Committee on Immunization Practices (ACIP) — November 20, 2025*
The American Public Health Association, along with 73 public health and health policy deans and scholars strongly believe that ACIP should maintain the current recommended hepatitis B vaccination schedule, which begins with a routine dose at the time of birth, because of the high level of protection it confers, the absence of evidence suggesting efficacy or safety concerns, and the risks of delaying infant immunization. Our comments focus on ACIP’s potential vote at their meeting on December 4, 2025 to revise its recommendation regarding administration of vaccines to protect infants and children against the hepatitis B virus. In considering this question, ACIP is carrying out its duties under law, and as such, must necessarily rely on its long-established scientific review process. This process has been designed to ensure that all recommendations rest on sound scientific evidence, with full consideration of risks and benefits.
Related resources:
GW Media Relations. December 2, 2025. https://mediarelations.gwu.edu/dozens-public-health-and-policy-experts-along-american-public-health-association-urge-cdc-maintain
Public comment letter in response to the Department of Health and Human Services’ Notice on Personal Responsibility and Work Opportunity Reconciliation Act Interpretation of “Federal Public Benefit” — August 13, 2025*
The American Public Health Association, the National Center for Medical-Legal Partnership, and the Jacobs Institute of Women’s Health, along with 63 public health deans and scholars strongly opposed HHS’s notice reinterpreting the definition of “federal public benefit” under the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA). This notice, based on flawed legal reasoning, reverses decades of long-standing policy without regard to the serious adverse impacts on individual and population health. This action will cause eligible immigrants and citizens to forgo necessary healthcare services, resulting in worsened health outcomes, increased uncompensated care costs, and harm to the U.S. economy. Additionally, restricted access to programs like Head Start, community health centers, and SAMHSA funded behavioral health services will worsen the children’s mental health crisis in America and disproportionately impact rural, low-income, and minority populations.
Public comment letter in response to the Department of Health and Human Services' Notice of Proposed Rulemaking on Section 1557 of the Affordable Care Act — September 29, 2022
The American Public Health Association and 66 public health deans and scholars strongly supported HHS’s proposed rule, “Nondiscrimination in Health Programs and Activities,” which would restore Section 1557’s protective umbrella against discrimination in all health programs or activities that receive funding under federal health programs administered by the Department. Among other suggestions, the comment recommends the meaning of sex-based discrimination be expanded to include discrimination based on pregnancy, and revisions to clarify that transgender status can constitute a separate and independent basis for enforcing the prohibition against withholding health services from an individual.
Public comment letter in response to the Internal Revenue Service's Notice of Proposed Rulemaking to address "Family Glitch" — June 6, 2022
The American Public Health Association and 63 public health deans and scholars supported the IRS’s effort to address the “family glitch,” which has barred many low- and moderate- income families from obtaining affordable health coverage. The agency’s proposed revisions would ensure the availability of affordable marketplace plans for the family members of workers who have been offered employer-sponsored coverage for their families but for whom family coverage remains unaffordable.
Public comment letter in response to the Department of Homeland Security's Notice of Proposed Rulemaking on the Public Charge Ground of Inadmissibility — April 22, 2022
66 public health deans and scholars supported DHS’s proposal to adopt an approach to the question of who can be considered a public charge that differs fundamentally from the policies previously in place under the now-vacated 2019 Final Rule. The DHS proposed rules would restore some certainty to U.S. law governing the definition of public charge and the process for making public charge determinations at the point of adjustment to permanent legal status. This step is urgently needed to begin to repair the considerable damage done by the 2019 rule, to reduce the unnecessary and harmful “chilling effect” of its policies and to improve immigrants’ ability to make economic progress and contribute to the United States.
Public Comment Letters on Section 1115 Medicaid Demonstration Waivers
Funding Acknowledgement
*Indicates public comments supported by the Commonwealth Fund, a national, private foundation based in New York City that supports independent research on health care issues and makes grants to improve health care practice and policy. The views presented here are those of the authors and not necessarily those of the Commonwealth Fund, its directors, officers, or staff.