Public Comment Letters
Public Comment Letters on Federal Regulations and Policies
Public comments from public health deans and scholars to federal agencies to inform significant public health and health care policies.
Petition to Amend the Vaccine Injury Table
May 15, 2026*^
A group of public health and administrative law scholars submitted a comment letter explaining the multiple legal and scientific flaws in a recent petition seeking to dramatically alter the scope of the National Childhood Vaccine Injury Act of 1986. The scholars warn that granting the petition’s request would risk alarming families by creating false impressions about links between vaccines and injuries, potentially discouraging the use of lifesaving vaccines.
- Related Resources
GW Media Relations. May 19, 2026. https://publichealth.gwu.edu/public-health-law-and-policy-experts-urge-secretary-robert-f-kennedy-jr-reject-latest-effort
Notice of Benefit and Payment Parameters 2027
March 13, 2026*^
31 public health and health policy deans, chairs, and scholars joined a comment letter on the Notice of Benefit and Payment Parameters for 2027, prepared by Jason Levitis, Sabrina Corlette, Lindsey Murtagh, and Claire O'Brien. The comment letter highlights how the proposed rule is a substantial step backward in affordability and access to health coverage and undermines key Affordable Care Act protections. Additionally, the rule would negatively impact the financial stability of health care providers and overall community health, especially in rural and low-income communities.
Artificial Intelligence in Clinical Care
February 23, 2026*^
125 public health and health policy deans, chairs, and scholars, filed a response to the Department of Health and Human Services’ request for information about accelerating the adoption and use of Artificial Intelligence (AI) as part of clinical care. Our response addresses patient privacy and data confidentiality issues, AI evaluation methods, where AI clinical tools have performed well and where they have fallen short, the challenges and concerns expressed by patients and caregivers, and published findings about the AI clinical care tools.
Medicaid Funding & Gender Affirming Care
February 17, 2026*^
APHA, along with 123 public health and health policy deans, chairs, and scholars submitted a comment opposing CMS’ proposal to prohibit Medicaid and CHIP funding for transition-related health care for transgender youth. CMS fails to sufficiently consider the significant negative impact that restricting access to this necessary, life-saving health care will have on individual and community health. If finalized as proposed, the rule would violate federal Medicaid law, including the requirement to provide medically necessary care under the Early and Periodic Screening, Diagnostic and Treatment requirement and Medicaid’s comparability requirements.
- Related Resources
GW Media Relations. February 17, 2026. https://mediarelations.gwu.edu/american-public-health-association-and-123-public-health-leaders-urge-centers-medicare-medicaid
Hospital Conditions of Participation
February 17, 2026*^
APHA along with 122 public health and health policy deans, chairs, and scholars submitted a comment opposing CMS’ proposal barring any hospital from participating in Medicare and Medicaid if it provides transition-related health care to transgender youth. The comment highlights the significant negative impacts that restricting access to this life-saving healthcare will have on individual health, community health, and state economies. The comment also details how CMS proposes this rule in violation of the Constitution, Medicare and Medicaid statutes, and the Administrative Procedure Act, infringing on certain powers reserved to Congress and the States.
Public Charge 2025
December 19, 2025*^
APHA and the Robert Wood Johnson Foundation, along with 65 public health and health policy deans, chairs, and scholars oppose DHS' proposal to rescind the 2022 Final Public Charge Rule without any replacement guidance. If finalized as proposed, the NPRM would grant immigration officers virtually unchecked authority over public charge determinations, leading to inconsistent, inaccurate, and arbitrary decisions. It will also 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.
- Related Resources
GW Media Relations. December 19, 2025. https://publichealth.gwu.edu/dozens-public-health-and-policy-experts-along-american-public-health-association-and-robert-wood
Medicaid Work Requirement Implementation
December 12, 2025*^
22 public health and health policy deans and scholars submit this comment to CMS to share relevant research findings and recommendations for implementing the new work requirements applying to Medicaid expansion adults. This comment focuses on the exemption for people who are “medically frail or otherwise have special medical needs.” Supporters of HR 1 assured people with disabilities and chronic illnesses that they would not be harmed by the Medicaid provisions of the bill. The comment details various recommendations to mitigate the chance that eligible people with disabilities and chronic illnesses lose coverage.
Advisory Committee on Immunization Practices
November 20, 2025*^
APHA, 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. ACIP 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
Supplemental Letter. December 3, 2025. https://hpmmatters.publichealth.gwu.edu/sites/g/files/zaxdzs6671/files/2026-01/ACIP%20HBV%20Supplemental%20Comment%20Letter.pdf
Neergaard, L. & Stobbe, M. What are parents to do as doctors clash with Trump administration over vaccines? AP News. Dec. 9, 2025. https://apnews.com/article/vaccine-safety-mmr-autism-rfk-hepatitis-20d3122d7a9a339cd8447a347bd49928
Szabo, L. Vaccinating newborns against hepatitis B saves lives. Why might a CDC panel stop recommending it? Center for Infectious Disease Research & Policy Research and Innovation Office, University of Minnesota. Dec. 3, 2025. https://www.cidrap.umn.edu/childhood-vaccines/vaccinating-newborns-against-hepatitis-b-saves-lives-why-might-cdc-panel-stop
PRWORA & "federal public benefit"
August 13, 2025*
APHA, 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 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 will disproportionately impact rural, low-income, and minority populations.
Section 1557 of the Affordable Care Act
September 29, 2022
APHA 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.
IRS' "Family Glitch"
June 6, 2022
APHA 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 Charge 2022
April 22, 2022
66 public health deans and scholars support 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. 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.
Section 1115 Medicaid Demonstration Waivers
April - July 2025
APHA and public health deans and scholars submitted various comment letters to CMS regarding state requests to require individuals to meet a work or community engagement requirement to qualify for and maintain Medicaid coverage. The states include Iowa, Arkansas, Arizona, Georgia, and Ohio.
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.
^Indicates support for this program is provided by the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the Robert Wood Johnson Foundation.