Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
Specialty Vehicle Groups Urge U.S. Forest Service to Expedite Post-Fire Recovery for Recreation
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WASHINGTON, Feb. 5 -- The Motorcycle Industry Council (MIC), Specialty Vehicle Institute of America (SVIA), and Recreational Off-Highway Vehicle Association (ROHVA) have issued a public comment letter to the U.S. Forest Service, advocating for quicker restoration of recreation opportunities following wildfires on National Forest System lands. This letter was prompted by the agency's Notice of Intent to Prepare an Environmental Assessment for Post-Fire Recovery Actions on National Forest System Lands.
The associations highlighted their commitment to promoting motorized access to public lands while
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WASHINGTON, Feb. 5 -- The Motorcycle Industry Council (MIC), Specialty Vehicle Institute of America (SVIA), and Recreational Off-Highway Vehicle Association (ROHVA) have issued a public comment letter to the U.S. Forest Service, advocating for quicker restoration of recreation opportunities following wildfires on National Forest System lands. This letter was prompted by the agency's Notice of Intent to Prepare an Environmental Assessment for Post-Fire Recovery Actions on National Forest System Lands.
The associations highlighted their commitment to promoting motorized access to public lands whileemphasizing the importance of protecting natural resources. With the outdoor recreation industry generating approximately $50.9 billion annually, the groups stressed the increasing popularity of motorized recreational activities, particularly off-highway vehicle use, and the necessity of maintaining access to affected areas.
In the letter signed by Duane Taylor, director of Safe and Responsible Use Programs, the organizations expressed support for the Forest Service's proposal to mitigate hazards from damaged trees that have fallen or are at risk of falling along roads and trails. While they recognize that such preventive actions may temporarily disrupt public access, they emphasized the necessity of restoring recreation infrastructure as rapidly as possible. The associations pointed to unfortunate instances, such as the prolonged closure of the Lefthand OHV Area in Colorado, to illustrate the need for timely re-openings.
The groups also aimed to direct attention to their readiness to assist in recovery efforts. They proposed leveraging the capabilities of the Post Wildfire OHV Recovery Alliance (PWORA), which was established to protect and restore off-highway vehicle recreation after disasters. By utilizing volunteer support for recovery actions, they believe that the process can be accelerated effectively.
Additionally, the associations called for the incorporation of wildfire mitigation strategies alongside the recovery efforts. They referenced a report titled "Trails and Resilience," which outlines how well-planned trails can enhance both recreation and emergency responses during extreme weather events. Highlighting the essential role of trails, they noted that future planning should prioritize the dual benefits of recreational and resilience-focused projects.
The organizations further noted various contributions made by powersports manufacturers in disaster relief efforts, emphasizing that collaboration with the Forest Service can facilitate swifter recovery and rejuvenation of recreational areas. They underscored the importance of integrating trails into comprehensive planning efforts to ensure accessibility and safety in anticipation of future natural disasters.
The associations concluded their letter by urging the Forest Service to consider all avenues for improving access to recreational opportunities in the wake of wildfires, thus fostering both enjoyment and protection of these vital public resources.
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The letter was signed by:
Duane Taylor
Director of Safe and Responsible Use Programs
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Read full text of letter here: https://www.regulations.gov/comment/FS-2025-0034-0080
Resound Research for Reproductive Health Urges CDC to Extend Pregnancy Risk Monitoring System
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WASHINGTON, Feb. 5 -- Resound Research for Reproductive Health, a project of the Tides Center, has submitted a public comment letter to the Centers for Disease Control and Prevention (CDC) advocating for the extension of the Pregnancy Risk Assessment Monitoring System (PRAMS) for an additional three years. The organization emphasizes the importance of this national and state-level data collection initiative that focuses on the health behaviors and experiences of women throughout their pregnancy journeys.
The letter highlights that PRAMS serves as a unique resource, gathering crucial data on essential
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WASHINGTON, Feb. 5 -- Resound Research for Reproductive Health, a project of the Tides Center, has submitted a public comment letter to the Centers for Disease Control and Prevention (CDC) advocating for the extension of the Pregnancy Risk Assessment Monitoring System (PRAMS) for an additional three years. The organization emphasizes the importance of this national and state-level data collection initiative that focuses on the health behaviors and experiences of women throughout their pregnancy journeys.
The letter highlights that PRAMS serves as a unique resource, gathering crucial data on essentialhealth screenings, insurance coverage, and maternal safety in relation to pregnancy and postpartum care. Researchers and public health practitioners rely on this data to identify risks, develop targeted health programs, and monitor local health policy effectiveness.
According to the organization, PRAMS data is vital in examining variations across states, allowing for meaningful comparisons that can lead to improved health strategies. The team has utilized PRAMS for research aimed at enhancing postpartum contraceptive access and addressing concerns related to short interpregnancy intervals. This capability to analyze state-level differences is viewed as crucial for tailoring health interventions to meet the needs of postpartum women.
In the letter, Resound advocates that continued investment in PRAMS is essential for maintaining maternal and infant health monitoring. Without this data source, the ability to inform evidence-based policies aimed at improving outcomes for families may be compromised. The organization underscores that the ongoing support for PRAMS is not just beneficial but necessary for public health advancements in maternal and infant care.
The CDC, responsible for overseeing the implementation of PRAMS, is now tasked with considering this request as it evaluates the future of the program. Advocacy from research-oriented organizations like Resound is pivotal in ensuring that comprehensive data collection continues to inform vital public health decisions. As the landscape of maternal health evolves, the need for reliable data remains critical in shaping policies that safeguard the well-being of mothers and infants across the nation.
Resound Research for Reproductive Health's appeal underscores a collective urgency among health professionals to reinforce the framework upon which maternal health initiatives are built.
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Read full text of letter here: https://www.regulations.gov/comment/CDC-2025-0750-0262
Oncology Nursing Groups Warn DOEd That "Professional Degree" Redefinition Could Worsen Nurse Shortage
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WASHINGTON, Feb. 5 -- The Oncology Nursing Society (ONS), along with the Oncology Nursing Certification Corporation (ONCC) and the Oncology Nursing Foundation (ONF), has submitted a public comment letter to the U.S. Department of Education expressing apprehensions regarding the proposed rule, Reimagining and Improving Student Education (RISE). Specifically, their concerns center around the proposed changes to the definition of "professional degree" programs, which they argue need substantial revisions to appropriately reflect the nuances of nursing education and practice.
The organizations assert
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WASHINGTON, Feb. 5 -- The Oncology Nursing Society (ONS), along with the Oncology Nursing Certification Corporation (ONCC) and the Oncology Nursing Foundation (ONF), has submitted a public comment letter to the U.S. Department of Education expressing apprehensions regarding the proposed rule, Reimagining and Improving Student Education (RISE). Specifically, their concerns center around the proposed changes to the definition of "professional degree" programs, which they argue need substantial revisions to appropriately reflect the nuances of nursing education and practice.
The organizations assertthat the current definition would exclude critical post-baccalaureate nursing programs, including the Master of Science in Nursing (MSN) and the Doctor of Nursing Practice (DNP). This exclusion, they say, relies too heavily on negotiated rulemaking consensus language and does not effectively represent the realities of nursing education and licensure. They believe that this definition does not contemplate the diverse roles and regulatory structures found within the nursing profession, which include both entry-level and advanced practice roles.
The letter emphasizes that while registered nurse (RN) licensure allows for general nursing practice, it does not extend to advanced practice roles, which require further education and training offered through MSN and DNP programs. The organizations argue that many students transition directly from a Bachelor of Science in Nursing into these advanced degree programs without practicing as RNs, reflecting a structure that should be recognized accordingly.
The agencies also highlight that the proposed definition lacks an understanding of the professional skills and academic rigor involved in post-baccalaureate nursing programs. They stress that MSN and DNP programs necessitate advanced coursework and extensive supervised clinical training surpassing that provided at the bachelor's level.
Furthermore, the letter warns that categorizing advanced nursing programs as graduate rather than professional degrees could diminish students' access to essential federal loan limits. This could especially impact those enrolled in rigorous accelerated or doctoral programs, thereby posing risks to nursing enrollment amid ongoing workforce shortages exacerbated by increasing demands for oncology care.
Both ONS, ONCC, and ONF urge the Department to reassess the proposed definition to ensure that it aligns with the established regulatory standards for professional degrees. They advocate for applying the existing definition at 34 C.F.R. Sec. 668.2 accurately to affirm the significance of advanced nursing education in addressing the healthcare needs of the nation moving forward.
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Read full text of letter here: https://www.regulations.gov/comment/ED-2025-OPE-0944-1214
Colorado Child Advocacy Groups Urge CDC to Maintain Vital Maternal Health Data Collection
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WASHINGTON, Feb. 5 -- Children's Hospital Colorado and the Colorado Children's Campaign have issued a public comment letter to the Centers for Disease Control and Prevention, advocating for the continuation of data collection for the Pregnancy Risk Assessment Monitoring System (PRAMS). The organizations emphasize the importance of this initiative for enhancing maternal and infant health outcomes.
In the letter, the organizations express appreciation for the opportunity to provide feedback on the proposed ongoing information collection for PRAMS. They highlight the program's role in helping healthcare
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WASHINGTON, Feb. 5 -- Children's Hospital Colorado and the Colorado Children's Campaign have issued a public comment letter to the Centers for Disease Control and Prevention, advocating for the continuation of data collection for the Pregnancy Risk Assessment Monitoring System (PRAMS). The organizations emphasize the importance of this initiative for enhancing maternal and infant health outcomes.
In the letter, the organizations express appreciation for the opportunity to provide feedback on the proposed ongoing information collection for PRAMS. They highlight the program's role in helping healthcareproviders enhance care delivery and empowering advocates to influence public health interventions and policy initiatives that promote healthy pregnancies and infants. Established in Colorado in 1996 following a grant from the CDC, PRAMS has been instrumental for nearly three decades in collecting and analyzing perinatal data essential for understanding maternal behaviors, healthcare access, and outcomes for women and infants.
The insight gained from PRAMS has enabled entities such as Children's Hospital Colorado and The Colorado Children's Campaign to collaborate with state agencies, lawmakers, and various stakeholders to evaluate and improve pregnancy outcomes. The Colorado Children's Campaign, for example, incorporates PRAMS data in its annual Kids Count in Colorado report, which tracks children's well-being and informs statewide and county-level needs. This reliable survey data is noted to be trusted by lawmakers on both sides of the aisle, making it crucial for informed policymaking in Colorado.
The organizations caution that discontinuing data collection through PRAMS would negatively impact maternal and infant health across the nation, as this system is the sole source of population-level perinatal data. Without this vital information, states like Colorado would struggle to guide and improve perinatal care effectively.
In closing, the letter reaffirms the organizations' strong support for the continuation of PRAMS data collection, stressing its critical role in ensuring the health of mothers and infants. The feedback submitted to the CDC is expected to influence ongoing discussions about public health initiatives essential for the well-being of families across the country.
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The letter was signed by:
Ellen Stern
Director of Government Affairs
Children's Hospital Colorado
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Toni Sarge
Director of Health Policy
Colorado Children's Campaign
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Read full text of letter here: https://www.regulations.gov/comment/CDC-2025-0750-0374
Arapahoe County Public Health Backs HHS Extension of PRAMS Data Collection Authority
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WASHINGTON, Feb. 4 -- Arapahoe County Public Health in Colorado has submitted a public comment letter to the U.S. Department of Health and Human Services expressing strong support for the extension of data collection authority for the Pregnancy Risk Assessment Monitoring System (PRAMS). This crucial surveillance system is recognized as a cornerstone of maternal and infant health monitoring across the nation.
PRAMS is among the few population-based data systems capable of capturing comprehensive information on maternal and child health. By linking self-reported data with birth records, the system
... Show Full Article
WASHINGTON, Feb. 4 -- Arapahoe County Public Health in Colorado has submitted a public comment letter to the U.S. Department of Health and Human Services expressing strong support for the extension of data collection authority for the Pregnancy Risk Assessment Monitoring System (PRAMS). This crucial surveillance system is recognized as a cornerstone of maternal and infant health monitoring across the nation.
PRAMS is among the few population-based data systems capable of capturing comprehensive information on maternal and child health. By linking self-reported data with birth records, the systemprovides invaluable insights into various health-related issues, including mental health, family planning, breastfeeding practices, and experiences of discrimination during pregnancy. The agency's support for extending PRAMS is rooted in the belief that uninterrupted data collection is essential for tracking trends, identifying disparities in infant outcomes, and informing evidence-based public health policy.
Arapahoe County Public Health specifically emphasized the critical role PRAMS data plays in local public health operations and planning. The data informs decisions related to Colorado's mandated Community Health Assessment and Community Health Improvement Plans, which prioritize local health issues based on assessed risks and outcomes. Insights into family planning trends derived from PRAMS data, for example, are essential for improving maternal and infant health outcomes by ensuring access to contraceptives and appropriate family planning services.
The agency highlighted how PRAMS data will support efforts outlined in legislation aimed at reducing severe maternal morbidity and mortality that may result from discrimination or bias. By collecting detailed information on maternal experiences during pregnancy and delivery, PRAMS offers data that cannot be captured by other means, like birth certificates, making it indispensable for evaluating progress and measuring disparities.
Arapahoe County Public Health noted the far-reaching implications of any disruption in PRAMS data collection. An interruption would greatly hinder the ability to monitor maternal health trends beyond hospital settings and evaluate the effectiveness of local programs. This would limit informed, data-driven decision-making regarding investments meant to support families and children.
Continuing PRAMS has been deemed vital for maintaining the integrity of maternal and infant health surveillance throughout the country. The extension of this program is imperative to ensure policymakers and public health agencies can access timely and reliable data, which is crucial for improving health outcomes and addressing the needs of vulnerable populations.
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The letter was signed by:
Alexa Escobar Paez, MPH
Sr. Population Health Epidemiologist
Arapahoe County Public Health
Arapahoe County, Colorado
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Read full text of letter here: https://www.regulations.gov/comment/CDC-2025-0750-0407
Glenn Brooks & Associates Warns Proposed Rule 45 Changes Could Jeopardize Due Process and Small Legal Businesses
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WASHINGTON, Feb. 4 -- Glenn Brooks & Associates has submitted a public comment letter to the Committee on Rules of Practice and Procedure at the Administrative Office of the United States Courts, expressing serious concerns regarding the proposed amendments to Federal Rule of Civil Procedure (FRCP) Rule 45. The organization argues that the changes would not only impact the professional process-serving industry economically, but also pose broader risks to due process and the reliability of subpoena enforcement.
The letter outlines that the proposed amendments would allow non-personal methods such
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WASHINGTON, Feb. 4 -- Glenn Brooks & Associates has submitted a public comment letter to the Committee on Rules of Practice and Procedure at the Administrative Office of the United States Courts, expressing serious concerns regarding the proposed amendments to Federal Rule of Civil Procedure (FRCP) Rule 45. The organization argues that the changes would not only impact the professional process-serving industry economically, but also pose broader risks to due process and the reliability of subpoena enforcement.
The letter outlines that the proposed amendments would allow non-personal methods suchas U.S. Mail and commercial carriers for serving subpoenas. This change, the organization argues, represents a significant departure from long-standing practices and may diminish the demand for traditional in-hand service. The expected fallout includes substantial revenue loss for many independent process servers and small agencies, ultimately endangering the livelihoods of those who have reliably served the federal judiciary for decades.
According to the organization, companies like theirs represent a considerable portion of process servers across the nation. The impending shift could reduce demand for traditional hand-delivery methods, threatening the economic stability of small, family-operated businesses that thrive on federal subpoena work. Independent process servers may struggle financially as the shift away from personal service disrupts established practice.
The comment letter raises additional alarms about systemic reliability and due-process concerns inherent in mail-based systems. The organization emphasizes that personal service is crucial for procedural fairness, noting that mail services have risks such as outdated addresses and mail verification issues. These complications place the onus on courts to verify service accuracy, potentially leading to disputes and noncompliance, which would in turn burden both litigants and the courts.
Further, the document points out that changes to the federal rules would likely influence state practices, as many states model their procedures on the FRCP. This effect could result in reduced demand for personal service in state courts and increase vendor automation, further eroding the role of skilled professionals in the justice system.
In conclusion, the organization urges the committee to reconsider the amendments to Rule 45 and to retain personal service as the standard delivery method for subpoenas. They call for a comprehensive economic impact assessment and additional testimony from affected professional associations before any changes are finalized. The impact of the proposed amendments could have far-reaching consequences for the integrity of the federal civil justice system and threaten the livelihoods of thousands of professionals nationwide.
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The letter was signed by:
Sheila Brooks
Owner, Glenn Brooks & Associates
4800 Whitesburg Drive, Suite 30-247
Huntsville, AL 35822
256-797-6200
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Read full text of letter here: https://www.regulations.gov/comment/USC-RULES-CV-2025-0004-0127
Gatzke Dillon & Ballance Challenges Oceano Dunes Conservation Plan, Warns It Overrestricts OHV Access and Local Recreation Economy
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WASHINGTON, Feb. 4 -- The law firm Gatzke Dillon & Ballance LLP has submitted a public comment letter to the U.S. Fish and Wildlife Service (USFWS) raising substantial concerns about the proposed Habitat Conservation Plan (HCP) and Environmental Assessment (EA) for the Oceano Dunes State Vehicle Recreation Area (ODSVRA). Representing EcoLogic Partners, Inc. and the Specialty Equipment Market Association, the firm highlighted potential conflicts between species protection measures and recreational access for off-highway vehicle (OHV) users.
The letter emphasizes the importance of recreational access
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WASHINGTON, Feb. 4 -- The law firm Gatzke Dillon & Ballance LLP has submitted a public comment letter to the U.S. Fish and Wildlife Service (USFWS) raising substantial concerns about the proposed Habitat Conservation Plan (HCP) and Environmental Assessment (EA) for the Oceano Dunes State Vehicle Recreation Area (ODSVRA). Representing EcoLogic Partners, Inc. and the Specialty Equipment Market Association, the firm highlighted potential conflicts between species protection measures and recreational access for off-highway vehicle (OHV) users.
The letter emphasizes the importance of recreational accessto public lands and critiques the HCP for failing to balance this access with the Endangered Species Act's requirements. According to the firm, the HCP overly relies on pessimistic assessments of OHV impacts on vulnerable species, which could disproportionately inhibit recreational opportunities. The proposed management measures are deemed excessively conservative, undermining the mandates set forth by California's Off-Highway Motor Vehicle Recreation Act.
In particular, the firm's analysis points out that the EA presents a flawed approach to restoring OHV access. It contends that the planned incremental reduction of seasonal exclosures at ODSVRA does not offer reliable assurance of recreational restoration, creating uncertainty and stability issues for OHV users.
Moreover, the firm criticizes the HCP's reliance on more than 500 Avoidance and Minimization Measures (AMMs), presuming severe restrictions on OHV activities without adequately assessing the impacts these measures would have on recreational opportunities. This focus is described as misdirected since existing data suggest that predator management, rather than increased OHV restrictions, has been key in improving nesting rates for protected bird species.
The letter also calls attention to the HCP's speculative take estimates for certain species, such as the Southwestern pond turtle, which are based on scant evidence. The organization argues that these estimations lead to unnecessary and draconian restrictions on OHV use, burdening outdoor recreation without justifiable cause.
Furthermore, the proposed creation of wide buffers around least tern nests and the insufficient analysis of socioeconomic impacts on local economies reliant on OHV use have also been flagged as critical issues. The firm stresses that local businesses in Pismo Beach significantly benefit from the recreational activities at the ODSVRA, and the EA must account for the potential economic implications of the HCP.
In conclusion, Gatzke Dillon & Ballance LLP argues that the current plans risk undermining the primary purpose of the ODSVRA, namely to facilitate public recreational activities, and insists on a revision of the EA to include alternatives that promote both conservation and access for outdoor enthusiasts.
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The letter was signed by:
David P. Hubbard
Of Gatzke Dillon & Ballance LLP
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Read full text of letter here: https://www.regulations.gov/comment/FWS-R8-ES-2025-0143-0026
Exploring New Horizons Outdoor Schools Opposes Offshore Oil and Gas Leasing Proposal
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WASHINGTON, Feb. 4 -- Exploring New Horizons Outdoor Schools has submitted a public comment letter to the Bureau of Ocean Energy Management, expressing strong opposition to Proposal MAA104000, which pertains to the 11th National Outer Continental Shelf Oil and Gas Leasing Draft Proposed Program. This nonprofit organization, based in Santa Cruz, California, focuses on fostering environmental stewardship and leadership among youth through immersive outdoor education experiences.
In the letter, Exploring New Horizons highlights how the proposed offshore oil and gas leasing fundamentally conflicts
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WASHINGTON, Feb. 4 -- Exploring New Horizons Outdoor Schools has submitted a public comment letter to the Bureau of Ocean Energy Management, expressing strong opposition to Proposal MAA104000, which pertains to the 11th National Outer Continental Shelf Oil and Gas Leasing Draft Proposed Program. This nonprofit organization, based in Santa Cruz, California, focuses on fostering environmental stewardship and leadership among youth through immersive outdoor education experiences.
In the letter, Exploring New Horizons highlights how the proposed offshore oil and gas leasing fundamentally conflictswith its mission to promote educational and environmental goals. The organization articulates concerns about the potential for increased oil spills, pollution, and industrial disturbances that could impact educational programs for nearly 9,000 students they serve across central and northern California. The letter emphasizes that healthy coastal ecosystems are vital for hands-on learning, which cultivates respect for the environment among students.
The outdoor school points out that offshore drilling poses serious risks, despite modern safeguards. Historical incidents have shown the possibility of catastrophic failures leading to long-term ecological damage, which could erase valuable natural classrooms relied upon by students nationwide. This degradation not only diminishes educational opportunities but also undermines public trust in the responsible management of marine resources.
Additionally, Exploring New Horizons stresses the urgency of rejecting the proposal in light of climate change. The letter notes that expanding fossil fuel development contradicts the scientific consensus advocating for a rapid decrease in greenhouse gas emissions. The impacts of climate change are already evident to the young people the organization educates, including rising sea levels and habitat loss. The organization insists federal policies should prioritize the protection of future generations by moving away from fossil fuel dependency.
The potential economic threats posed by offshore oil and gas development also concern the organization. With tourism, recreation, and fishing being key components of coastal economies, Exploring New Horizons urges that the risks associated with environmental degradation could inflict lasting economic and educational harm that outweighs any temporary leasing benefits.
In conclusion, Exploring New Horizons Outdoor Schools calls on the Bureau of Ocean Energy Management to withdraw Proposal MAA104000 and consider alternatives focused on renewable energy, conservation, and climate resilience. The organization appeals for policies that align with long-term public interests and safeguard coastal ecosystems for future generations.
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The letter was signed by:
Joshua Lanam
Executive Director
Exploring New Horizons Outdoor Schools
101 Cooper Street, Santa Cruz, California 95060
(831) 252-6685
info@exploringnewhorizons.org
Nonprofit Tax ID 94-2618650
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Read full text of letter here: https://www.regulations.gov/comment/BOEM-2025-0483-5028
Center for Regulatory Freedom Backs OCC Proposal to Ease Licensing Rules for Community Banks
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WASHINGTON, Feb. 4 -- The Center for Regulatory Freedom (CRF), part of the American Conservative Union Foundation, has submitted a public comment letter to the U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), expressing strong support for proposed Community Bank Licensing Amendments. These amendments aim to revise regulatory requirements for community national banks and community federal savings associations in a manner that acknowledges their unique role in providing essential credit services to local markets.
In its commentary, CRF emphasizes that community
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WASHINGTON, Feb. 4 -- The Center for Regulatory Freedom (CRF), part of the American Conservative Union Foundation, has submitted a public comment letter to the U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), expressing strong support for proposed Community Bank Licensing Amendments. These amendments aim to revise regulatory requirements for community national banks and community federal savings associations in a manner that acknowledges their unique role in providing essential credit services to local markets.
In its commentary, CRF emphasizes that communitybanks are integral to the financial system, often serving customers and local businesses that larger institutions may overlook. The organization highlighted that by introducing more flexible licensing procedures, the OCC is recognizing the diverse needs of smaller institutions and their importance in fostering competition, consumer choice, and local economic stability.
CRF advocates against a uniform regulatory approach, which it argues imposes disproportionate burdens on lower-risk community banks. The letter points out that uniform licensing requirements can divert critical resources away from lending and innovation. By extending expedited filing procedures specifically to well-capitalized and well-managed community institutions, the proposal affirms that regulatory oversight can be both efficient and effective. This approach allows regulatory processes to focus on institutions based on their risk profiles, thereby enhancing overall supervisory effectiveness.
The organization also noted that adjusting these licensing requirements is vital for reducing administrative costs-potentially redirecting savings to enhance local lending practices and service offerings. The amendments not only aim to alleviate regulatory pressures but also pledge to preserve strict safety and soundness standards, ensuring that the OCC remains equipped to monitor higher-risk activities closely.
Furthermore, CRF praised the OCC for attempting to clarify when an adverse public comment should be deemed significant. The proposed clarification is believed to enhance transparency in the licensing process while limiting potential misuse of the public comment period that could lead to unnecessary delays.
As community banks increasingly face challenges from heavy regulatory burdens, CRF urges the OCC to swiftly finalize these amendments to bolster access to credit for underserved communities. By implementing these licensing reforms, the OCC can support a more adaptable and resilient banking framework that prioritizes the delivery of diverse financial services to local economies.
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The letter was signed by:
Andrew M. Langer
Director
CPAC Foundation Center for Regulatory Freedom
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Read full text of letter here: https://www.regulations.gov/comment/OCC-2025-0273-0004
Carlsmed Urges CMS To Recognize Importance of Cervical Device Classification
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WASHINGTON, Feb. 4 -- Carlsmed, Inc., a company in the field of spinal fusion technology, has issued a public comment letter to the Centers for Medicare & Medicaid Services (CMS) regarding the Medicare Hospital Outpatient Prospective Payment System (OPPS) final rule for Calendar Year 2026. The letter emphasizes the necessity for CMS to accurately categorize its innovative aprevo(R) devices, particularly the aprevo(R) Cervical ACDF System, to enhance patient access and outcomes.
In its letter, Carlsmed highlighted that its aprevo(R) device recently earned the Food and Drug Administration's (FDA)
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WASHINGTON, Feb. 4 -- Carlsmed, Inc., a company in the field of spinal fusion technology, has issued a public comment letter to the Centers for Medicare & Medicaid Services (CMS) regarding the Medicare Hospital Outpatient Prospective Payment System (OPPS) final rule for Calendar Year 2026. The letter emphasizes the necessity for CMS to accurately categorize its innovative aprevo(R) devices, particularly the aprevo(R) Cervical ACDF System, to enhance patient access and outcomes.
In its letter, Carlsmed highlighted that its aprevo(R) device recently earned the Food and Drug Administration's (FDA)Breakthrough Device Designation, underscoring its unique advantages in patient-specific spine surgeries. The company attributes a remarkable 83% reduction in reoperations among patients using this technology at the two-year mark. Despite the higher initial costs associated with the aprevo(R) implant, Carlsmed argues that this investment leads to decreased overall healthcare expenditures due to fewer complications and hospital stays.
The company has expressed its concern that patient access to this technology is jeopardized. Carlsmed warned that current CMS payment policies do not adequately reflect the actual costs associated with providing the superior cervical technology to Medicare beneficiaries. It appealed to the agency to re-evaluate its classification of the cervical device under existing codes, emphasizing that the aprevo(R) Cervical ACDF System is materially distinct from an expired category focused solely on lumbar applications.
Carlsmed noted that CMS has previously established separate categories for devices based on anatomical differences, and it cited multiple precedents to support the establishment of new classifications for its products. The company also pointed out that the recent approval of the aprevo(R) cervical device for New Technology Ambulatory Payment Classification (APC) illustrates its clinical and economic distinctions within the regulatory framework.
Additionally, Carlsmed has submitted requests for CMS to create New Technology APC assignments for both the lumbar and cervical devices as a pathway to ensure beneficiary access. The company asserts that the quicker these classifications are established, the sooner access to this innovative spinal fusion technology can improve patient outcomes and reduce costs for the Medicare program.
Carlsmed remains committed to working with CMS to facilitate the recognition and appropriate classification of its technology, which promises not only to enhance surgical outcomes but also to streamline costs associated with spinal fusion surgeries for Medicare beneficiaries.
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The letter was signed by:
Sharon Schulzki
Chief Clinical and Market Access Officer
Carlsmed, Inc.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2025-0306-3104
BlueRibbon Coalition Urges Fish & Wildlife Service to Preserve Motorized Recreation in Oceano Dunes Habitat Conservation Plan
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WASHINGTON, Feb. 4 -- BlueRibbon Coalition (BRC), a national nonprofit organization dedicated to responsible recreation and conservation, has submitted a public comment letter to the U.S. Fish and Wildlife Service. The organization expressed its views on the ongoing discussions surrounding the Habitat Conservation Plan and the associated incidental take permit for the Oceano Dunes area in California.
The BRC emphasizes the importance of motorized recreation at Oceano Dunes, where many of its members engage in activities such as off-highway vehicle riding, camping, and wildlife observation. The
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WASHINGTON, Feb. 4 -- BlueRibbon Coalition (BRC), a national nonprofit organization dedicated to responsible recreation and conservation, has submitted a public comment letter to the U.S. Fish and Wildlife Service. The organization expressed its views on the ongoing discussions surrounding the Habitat Conservation Plan and the associated incidental take permit for the Oceano Dunes area in California.
The BRC emphasizes the importance of motorized recreation at Oceano Dunes, where many of its members engage in activities such as off-highway vehicle riding, camping, and wildlife observation. Theorganization argues that the current Endangered Species Act (ESA) regulations should not serve as a fixed baseline for land use decisions. They highlight that ongoing revisions to ESA regulations indicate the need for flexibility and adaptability in management strategies.
Responding to opposition comments that advocate for the denial of the incidental take permit, BRC argues that such actions would create more legal uncertainty and managerial challenges. The organization points out that denying the permit would not necessarily prevent harm to the environment but would instead hinder a structured approach that promotes monitoring and mitigation of ecological impacts.
BRC also rejects calls for expanded closures around the Oceano Dunes, asserting that such measures lack scientific justification and do not offer proven conservation benefits. They stress that any closure should be tied to measurable biological objectives and reassessed when goals are met. The group contends that imposing restrictions without data-driven validation not only undermines public trust but also contravenes the principles of sound scientific management.
In line with the enacted Expanding Public Lands Outdoor Recreation Experiences Act, BRC urges the agency to consider the benefits of recreational access alongside conservation goals. They highlight the economic benefits that motorized recreation brings to local communities and the need for balancing environmental protection with recreational opportunity.
BRC advocates for an incidental take permit that accommodates continued motorized recreation under a compliant and adaptive framework, ensuring that conservation measures do not come at the expense of lawful public use. The organization also declares its support for organized events in the area, viewing them as integral to the rights of freedom of assembly and speech.
As the U.S. Fish and Wildlife Service works on finalizing the Habitat Conservation Plan, the BRC's comments illustrate a steadfast push for policies that support outdoor recreation while aiming for meaningful conservation measures. The outcomes of this process will have lasting implications for community engagement and responsible public land use in California.
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The letter was signed by:
Ben Burr
Executive Director
BlueRibbon Coalition
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Simone Griffin
Policy Director
BlueRibbon Coalition
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Read full text of letter here: https://www.regulations.gov/comment/FWS-R8-ES-2025-0143-0029
Arapahoe County Public Health Backs HHS Extension of PRAMS Data Collection Authority
Carter Struck
WASHINGTON, Feb. 4 -- Arapahoe County Public Health in Colorado has submitted a public comment letter to the U.S. Department of Health and Human Services expressing strong support for the extension of data collection authority for the Pregnancy Risk Assessment Monitoring System (PRAMS). This crucial surveillance system is recognized as a cornerstone of maternal and infant health monitoring across the nation.
PRAMS is among the few population-based data systems capable of capturing comprehensive information on maternal and child health. By linking self-reported data with birth records, the system
... Show Full Article
WASHINGTON, Feb. 4 -- Arapahoe County Public Health in Colorado has submitted a public comment letter to the U.S. Department of Health and Human Services expressing strong support for the extension of data collection authority for the Pregnancy Risk Assessment Monitoring System (PRAMS). This crucial surveillance system is recognized as a cornerstone of maternal and infant health monitoring across the nation.
PRAMS is among the few population-based data systems capable of capturing comprehensive information on maternal and child health. By linking self-reported data with birth records, the systemprovides invaluable insights into various health-related issues, including mental health, family planning, breastfeeding practices, and experiences of discrimination during pregnancy. The agency's support for extending PRAMS is rooted in the belief that uninterrupted data collection is essential for tracking trends, identifying disparities in infant outcomes, and informing evidence-based public health policy.
Arapahoe County Public Health specifically emphasized the critical role PRAMS data plays in local public health operations and planning. The data informs decisions related to Colorado's mandated Community Health Assessment and Community Health Improvement Plans, which prioritize local health issues based on assessed risks and outcomes. Insights into family planning trends derived from PRAMS data, for example, are essential for improving maternal and infant health outcomes by ensuring access to contraceptives and appropriate family planning services.
The agency highlighted how PRAMS data will support efforts outlined in legislation aimed at reducing severe maternal morbidity and mortality that may result from discrimination or bias. By collecting detailed information on maternal experiences during pregnancy and delivery, PRAMS offers data that cannot be captured by other means, like birth certificates, making it indispensable for evaluating progress and measuring disparities.
Arapahoe County Public Health noted the far-reaching implications of any disruption in PRAMS data collection. An interruption would greatly hinder the ability to monitor maternal health trends beyond hospital settings and evaluate the effectiveness of local programs. This would limit informed, data-driven decision-making regarding investments meant to support families and children.
Continuing PRAMS has been deemed vital for maintaining the integrity of maternal and infant health surveillance throughout the country. The extension of this program is imperative to ensure policymakers and public health agencies can access timely and reliable data, which is crucial for improving health outcomes and addressing the needs of vulnerable populations.
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The letter was signed by:
Alexa Escobar Paez, MPH
Sr. Population Health Epidemiologist
Arapahoe County Public Health
Arapahoe County, Colorado
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Read full text of letter here: https://www.regulations.gov/comment/CDC-2025-0750-0407
