On May 1, 2018, the Health Resources and Services Administration (HRSA) released a wide-ranging Request for Information (RFI) asking members of the public to provide input on changes that HRSA can make that “would result in a more streamlined, flexible, and less burdensome compliance and reporting structure.” The effort seeks to identify deregulatory actions affecting sub-regulatory guidance and guidance documents.
The RFI identifies opportunities specific to the HIV/AIDS Bureau (HAB) and Ryan White HIV/AIDS Program (RWHAP). Specifically, HAB is interested in feedback on:
- Waivers of the 75% core medical service requirement applicable to Part A, B, and C grantees, and the reasonableness of the waiver request process;
- Changes to client-level reporting that could include detailed information on how rebates and program income are expended; and
- Minimizing the impact of RWHAP eligibility certification on patients.
RWHAP grantees and stakeholders also might wish to comment on other administrative elements of the program, including issues surrounding program income, the role of the 340B program, covered services, and eligible beneficiaries. While some limitations are necessary under the RWHAP statutes, grantees and subgrantees have the opportunity under this RFI to comment on overly broad or overly restrictive Policy Clarification Notices (PCNs) and other guidance.
If you are interested in submitting a comment or have any questions regarding the RFI, please contact Jason Reddish, Scott Sheffler, or the Feldesman Tucker attorney with whom you typically work. Mr. Reddish and Mr. Sheffler also conduct intensive two-day trainings on RWHAP program income tracking and management. Additional details and information regarding registration for the next session, being held on June 5 and 6 in Washington, D.C., can be found here.