• Analysis or Summary
  • December 23, 2020

CHA Submits Comments to HHS on Innovative Practices and Emergency Flexibilities in Response to COVID-19

On Dec. 23, we submitted comment letters to HHS on two requests for information (RFIs) seeking feedback from health care stakeholders on innovative best practices and programs implemented in response to COVID-19, as well as feedback on the continuation of emergency flexibilities granted during the COVID-19 public health emergency (PHE). 

  • RFI on health care best practices and innovations in response to COVID-19 – our comments provide details on policies and programs children’s hospitals have modified in response to COVID-19 related to behavioral health and telehealth-focused actions. We also highlight the need for long-term investments in children’s behavioral health. 
  • RFI on continuation of emergency flexibilities – our comments provide recommendations and considerations to HHS focused on the maintenance of certain flexibilities granted during the PHE related to audio-only services; elimination of prior authorization requirements; 12-month continuous Medicaid and CHIP eligibility for children; and telehealth payment.

We thank those children’s hospitals that provided feedback to inform our comments.

CHA Contacts: Hilary Daniel and Rachel Bonesteel