Public Comments

PHLW has created a toolkit with information on the rulemaking process and public comments, including information on how to write public comments and how to host a comment-writing party.

Public comments for which PHLW was a drafter, signatory, and/or affiliate:

• Public Health Law Watch, Comments in Response to Interim Final Rule: Visas: Ineligibility Based on Public Charge Grounds (11/12/2019).

  In response to the federal State Department's proposed public charge regulation changes, which denied entry to immigrants based on their anticipated use of public benefits, PHLW highlighted adverse impacts on the healthcare system. In particular, PHLW emphasized likely reductions in the already-deficient number of health care workers in the U.S. due to the rule's immigration restrictions, given the large percentage of immigrants who currently make up the health care workforce. PHLW urged the State Department to withdraw the proposed public charge rule. Although the rule took effect in February 2020, litigation around the public charge rule is still ongoing.

• Center for Health Policy and Law and Center for Public Interest Advocacy and Collaboration at Northeastern University School of Law and Public Health Law Watch, Comments in Response to Proposed Rulemaking: Inadmissibility on Public Charge Grounds (12/07/2018).

  In December 2018, the Center for Health Policy and Law, the Center for Public Interest Advocacy and Collaboration, and Public Health Law Watch submitted a public comment regarding proposed public charge regulations by the Department of Homeland Security. We emphasized the proposed rule's impact on declines in health insurance coverage, deterrence of healthcare for people with preventable health conditions, including infectious diseases, strain on health care workers, and social determinants of health. The rule was implemented in February 2020. Litigation around the rule is ongoing, and after an initial injunction, DHS was allowed to resume implementation nationwide in September 2020.

• Center for Health Policy and Law at Northeastern University School of Law and Public Health Law Watch, Public Comment on Proposal to Revise Title X Regulations, Compliance with Statutory Program Integrity Requirements (07/31/2018).

  The Center for Health Policy and Law and Public Health Law Watch submitted a public comment regarding proposed HHS revisions to 45 CFR Part 59, "Compliance with Statutory Program Integrity Requirements." Specifically, we voiced concerns regarding the proposed regulations' failure to provide "conscience protections" for providers to provide medically-appropriate information to patients about abortions. Although HHS proceeded with its "conscience rule" changes, the rule met multiple federal court challenges and was blocked in New York in November 2019.