Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
Absolute Best Insurance Medicare Agent Urges CMS to Reform 2027 Medicare Advantage and Part D Rule
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WASHINGTON, March 27 -- Clare Goyette, an independent Medicare insurance agent with Absolute Best Insurance, Greenacres, Florida, submitted a public comment letter to the U.S. Department of Health and Human Services' Centers for Medicare & Medicaid Services regarding the 2027 Medicare Advantage and Part D proposed rule, outlining concerns about regulatory requirements affecting agents and beneficiaries.
The letter criticizes insurance carriers' control over which plans agents can present to beneficiaries, which limits comprehensive plan comparisons and may steer individuals away from optimal coverage.
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WASHINGTON, March 27 -- Clare Goyette, an independent Medicare insurance agent with Absolute Best Insurance, Greenacres, Florida, submitted a public comment letter to the U.S. Department of Health and Human Services' Centers for Medicare & Medicaid Services regarding the 2027 Medicare Advantage and Part D proposed rule, outlining concerns about regulatory requirements affecting agents and beneficiaries.
The letter criticizes insurance carriers' control over which plans agents can present to beneficiaries, which limits comprehensive plan comparisons and may steer individuals away from optimal coverage.It calls for a prohibition on carriers restricting agents' ability to offer all available plans, emphasizing the need for unbiased, beneficiary-centered guidance in a competitive marketplace. Furthermore, the letter identifies the requirement for separate annual certifications with each carrier as a major administrative challenge that consumes valuable time better spent serving beneficiaries. A centralized CMS certification process, modeled on Healthcare.gov, is proposed to streamline certification, broaden agent access to all plans including regional offerings, and level the playing field.
CMS's call recording mandate is described as particularly onerous, requiring specialized technology and complex legal compliance. The agent urges the removal of this requirement or, alternatively, recommends reducing the retention period for recorded calls from ten years to two years to ease storage burdens while maintaining oversight capabilities. Similarly, the Scope of Appointment (SOA) protocol is deemed an unnecessary administrative hurdle unique to agents and advocates for its elimination or at least the removal of the 48-hour waiting rule to enable more timely beneficiary assistance.
The letter also addresses the overly broad definition of Third-Party Marketing Organizations (TPMOs) and calls for distinct categories tailored to lead generators, independent agents, and captive agents. It emphasizes the importance of stringent oversight of lead generators, including mandatory traceability of consent and restrictions on foreign-based operations, citing beneficiary protection concerns. The letter criticizes CMS's reliance on carriers to police misconduct, arguing that a direct reporting mechanism to CMS is essential to ensure accountability and program integrity.
Additional recommendations include expanding beneficiary access to timely plan information via open data and technological innovation, establishing a special enrollment period for provider network terminations, revising the TPMO disclaimer to avoid misleading statements by agents, eliminating the 12-hour delay between education and enrollment discussions, and relaxing record retention from ten to two years.
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2025-1393-16650
Advocate Health Urges CMS to Preserve Key Measures and Enhance Medicare Advantage Well-Being Initiatives
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WASHINGTON, March 27 -- Advocate Health, a leading nonprofit integrated health system headquartered in Charlotte, North Carolina, submitted a public comment letter to the Centers for Medicare and Medicaid Services addressing the agency's proposed Contract Year 2027 policy changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and Medicare Cost Plan Program. Advocate Health expressed support for CMS's efforts to reduce administrative burden, improve patient outcomes, and enhance access to care, while emphasizing the importance of a cautious, phased approach to reforms
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WASHINGTON, March 27 -- Advocate Health, a leading nonprofit integrated health system headquartered in Charlotte, North Carolina, submitted a public comment letter to the Centers for Medicare and Medicaid Services addressing the agency's proposed Contract Year 2027 policy changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and Medicare Cost Plan Program. Advocate Health expressed support for CMS's efforts to reduce administrative burden, improve patient outcomes, and enhance access to care, while emphasizing the importance of a cautious, phased approach to reformsaffecting quality metrics and risk adjustment methods.
In its comments, Advocate Health endorsed CMS's proposal to streamline the Star Ratings program by removing some measures that are no longer effective in distinguishing plan performance. The organization highlighted the value of adding a Depression Screening and Follow-Up measure, which aligns with its priorities to integrate behavioral health. Nevertheless, Advocate Health opposed the removal of the Reviewing Appeals Decisions (Part C) measure, warning that its elimination could undermine beneficiary protections, increase inappropriate denials, and elevate administrative burdens for patients and providers. Additional opposition was expressed regarding the proposed removal of certain measures related to timely decisions and Independent Review Entity performance, which Advocate Health believes are essential to maintaining oversight and preventing gaming by Medicare Advantage Organizations.
Regarding enrollment policies, Advocate Health backed the expansion of Special Enrollment Periods for beneficiaries affected by provider network changes, urging CMS to monitor implementation to avoid disruptions in care coordination. The health system also supported ongoing Part D reforms under the Inflation Reduction Act that improve drug affordability by eliminating the coverage gap and capping out-of-pocket costs.
Advocate Health emphasized the need for robust Medical Loss Ratio (MLR) reporting to monitor potential overpayment risks tied to increasing vertical integration within the Medicare Advantage market. The organization urged CMS to collect granular data on negotiated rates for provider groups owned or affiliated with payers to ensure enforcement of MLR standards.
The letter called on CMS to enhance network adequacy oversight for Part D plans, particularly to ensure consistent access to long-term care pharmacies for nursing home and waiver populations. Specific recommendations included finalizing network adequacy prior to open enrollment, requiring detailed reporting on long-term care pharmacy networks, conducting routine audits, implementing enforcement mechanisms, and mandating public disclosure of network information.
On risk adjustment modernization, Advocate Health supported efforts to reduce documentation burden and promote equity but cautioned against abrupt transitions that could destabilize value-based care arrangements. The organization implored CMS to provide multi-year advance notice, hold-harmless provisions, transparent modeling, financial transition support, and appeal mechanisms to safeguard providers and beneficiaries during any changes.
The letter also addressed reforms to the Quality Bonus Payment system and Star Ratings, calling for gradual implementation of measure deletions, stability in bonus thresholds, and policies to smooth year-over-year changes. Advocate Health encouraged CMS to incorporate incentives that promote collaboration between Medicare Advantage plans and health systems to enhance clinical outcomes and cost efficiency.
In response to CMS's request for input on integrating well-being measures into Medicare Advantage, Advocate Health expressed strong support for expanding focus beyond clinical care to include nutrition, physical activity, sleep quality, and social connection. The organization recommended screening beneficiaries for nutritional risk, food insecurity, social isolation, and sleep disorders using validated tools, and offering targeted interventions such as Medical Nutrition Therapy, fitness programs, sleep assessments, and social engagement activities. Advocate Health urged CMS to establish process and outcome quality measures to monitor these efforts and to publish standardized screening instruments to ensure consistency across plans.
Furthermore, Advocate Health recommended flexible supplemental benefits and expanded safe harbor protections to enable innovative services addressing well-being domains. The health system highlighted the importance of partnerships among Medicare Advantage plans, health systems, and community organizations, with shared data systems, coordinated care infrastructure, joint accountability, and sustainable funding to successfully implement well-being initiatives.
The health system concluded by reaffirming its commitment to supporting CMS's work to advance care quality, reduce healthcare costs, improve chronic condition management, and expand access to preventive services within Medicare Advantage and the broader Medicare program.
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The letter was signed by:
Meghan C. Woltman
SVP, Chief Government Affairs Officer
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2025-1393-17346
AdventHealth Urges CMS to Revise Medicare Advantage Risk-Adjustment Model to Include Chronic Conditions
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WASHINGTON, March 27 -- AdventHealth submitted a public comment letter to the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services advocating for changes to the Medicare Advantage (MA) risk-adjustment model ahead of the 2027 contract year. The healthcare system, which operates more than 55 hospitals across nine states and serves a large population of Medicare Advantage beneficiaries, expressed concerns that the current V28 risk-adjustment model inadequately accounts for the severity of certain chronic conditions, leading to underpayments for providers managing
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WASHINGTON, March 27 -- AdventHealth submitted a public comment letter to the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services advocating for changes to the Medicare Advantage (MA) risk-adjustment model ahead of the 2027 contract year. The healthcare system, which operates more than 55 hospitals across nine states and serves a large population of Medicare Advantage beneficiaries, expressed concerns that the current V28 risk-adjustment model inadequately accounts for the severity of certain chronic conditions, leading to underpayments for providers managingcomplex patients.
AdventHealth emphasized the crucial role of accurate risk adjustment in reflecting patient acuity and resource needs, noting that previous reductions or eliminations of certain chronic condition codes in the V28 model had significant financial impacts on providers dedicated to caring for the most vulnerable populations. The organization noted it experienced an estimated $12 million loss as a result of these changes while expanding primary care access.
The letter highlighted several chronic conditions that were excluded from the V28 model but remain prevalent and costly within AdventHealth's senior patient population. These conditions include Diabetes with Complications, Major Depression, Angina, and Vascular Disease. According to AdventHealth, 46% of seniors in their primary care clinics have been diagnosed with at least one of these conditions, underscoring their clinical and financial importance.
AdventHealth provided detailed evidence of the higher medical expenditures associated with diabetes complications, demonstrating that costs for patients with complications are approximately 2.6 times greater than those without. Kidney disease was noted as a particularly expensive complication. The organization also stressed the ongoing need to manage major depression due to its potential to worsen mental and physical health outcomes, which contributes to elevated healthcare utilization.
Regarding angina, AdventHealth appealed to CMS to recognize the significant impacts of inadequate treatment, which can lead to costly emergency admissions and complex procedures. The letter further cited vascular disease as a condition requiring active management to prevent severe cardiovascular events.
The healthcare system acknowledged CMS's efforts to strengthen the MA program and encouraged further collaboration, offering to connect the agency with frontline physicians experienced in managing these chronic conditions. AdventHealth reaffirmed its commitment to enhancing community health through prevention and management of chronic diseases, aiming to reduce hospitalizations and foster better care outcomes under Medicare Advantage.
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The letter was signed by:
Michael E. Griffin
Senior Vice President
Advocacy and Public Policy
AdventHealth
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2025-1393-16277
Acumen LLC Urges CMS to Reform Medicare Advantage Risk Adjustment to Reduce Overpayments
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WASHINGTON, March 27 -- Acumen LLC submitted a public comment letter to the Centers for Medicare & Medicaid Services outlining recommendations to address persistent overpayments in Medicare Advantage plans, focusing on risk adjustment, quality incentives and the role of clinical data in payment models.
Acumen highlights that MA plans consistently receive higher payments on a risk-adjusted basis, with risk scores approximately 16% greater than those of similar FFS beneficiaries. This discrepancy stems from incentives in MA to code diagnoses more intensively, whereas FFS providers, reimbursed based
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WASHINGTON, March 27 -- Acumen LLC submitted a public comment letter to the Centers for Medicare & Medicaid Services outlining recommendations to address persistent overpayments in Medicare Advantage plans, focusing on risk adjustment, quality incentives and the role of clinical data in payment models.
Acumen highlights that MA plans consistently receive higher payments on a risk-adjusted basis, with risk scores approximately 16% greater than those of similar FFS beneficiaries. This discrepancy stems from incentives in MA to code diagnoses more intensively, whereas FFS providers, reimbursed basedon services rather than diagnoses, may underreport conditions. The firm emphasizes that whether this is due to overcoding by MA plans or underreporting by FFS providers, the current risk adjustment system lacks alignment with clinical realities.
The company recommends CMS explore four key improvements. First, integrating clinical services data to substantiate diagnoses and indicate severity, thus increasing alignment with FFS Medicare. Second, employing clinical episodes of care to better capture patient risk profiles by reflecting comprehensive longitudinal care patterns, which can deter gaming of the system. Third, introducing ex post risk adjustment revisions to avoid payments for conditions not requiring substantial care, thereby encouraging appropriate care delivery and improving quality. Fourth, avoiding overly complex or burdensome data collection and opaque algorithms that hinder transparency and create competitive disadvantages for smaller MA plans.
On addressing diagnoses in risk adjustment, Acumen advises limiting reliance on diagnoses from less clinically meaningful encounters such as in-home health assessments and chart reviews, and requiring multiple encounters or clinical services to confirm chronic conditions. The firm also advocates for CMS to incorporate clinical episodes as a robust method for identifying conditions and assessing severity.
Regarding alternative risk adjustment methods, Acumen suggests CMS shift towards models based on actual healthcare utilization and clinical episodes rather than solely on diagnosis codes, which are prone to manipulation. The company cautions against adopting artificial intelligence for risk adjustment due to transparency issues but sees potential in using AI for detecting fraud and abuse.
Acumen urges CMS to make fuller use of existing data sources, such as prescription drug event data and already collected clinical services data, while warning against incorporating additional data types like electronic medical records or surveys due to practicality concerns.
Finally, Acumen proposes ex post payment adjustments tied to clinical care and quality performance as a means to promote cost containment and high-value care in the Medicare Advantage program. This approach could better align incentives toward improving beneficiary outcomes rather than focusing on maximizing payments through coding practices.
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The letter was signed by:
Felix Tismer
Chief Financial Officer
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2025-1393-17198
6 Democratic Caucus Members Opposes HHS Rule Targeting Women's Health Care Access
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WASHINGTON, March 27 -- 6 Members of the Democratic Women's Caucus and Reproductive Freedom Caucus submitted a public comment letter to the U.S. Department of Health and Human Services opposing a proposed rule on health coverage and payment parameters for 2027, arguing it would increase costs and restrict access to care for women and families.
In their communication with HHS, the caucus articulates that this proposed rule is misleadingly portrayed as a means to reduce costs. Instead, it is believed to steer individuals toward catastrophic insurance plans, which often plunge enrollees into higher
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WASHINGTON, March 27 -- 6 Members of the Democratic Women's Caucus and Reproductive Freedom Caucus submitted a public comment letter to the U.S. Department of Health and Human Services opposing a proposed rule on health coverage and payment parameters for 2027, arguing it would increase costs and restrict access to care for women and families.
In their communication with HHS, the caucus articulates that this proposed rule is misleadingly portrayed as a means to reduce costs. Instead, it is believed to steer individuals toward catastrophic insurance plans, which often plunge enrollees into higherout-of-pocket expenses due to steep deductibles and inadequate pre-deductible coverage. As a result, those who opt for these plans could find themselves severely underinsured, facing exorbitant costs before any benefits kick in.
The group highlights the disproportionate impact these rule changes could have on women, who are often the primary decision-makers in health care within families, as well as the financial overseers. They assert that the rule's ramifications would force pregnant individuals and new mothers into dire financial situations when facing childbirth costs, which average over $20,000 in the U.S. Such circumstances threaten not just individual health outcomes but also the overall financial viability of families.
Furthermore, the proposed changes are criticized for jeopardizing the minimum contracting threshold for Essential Community Providers (ECPs), which are pivotal in ensuring access to family planning services and preventive care. By reducing this threshold from 35% to 20%, the proposed rule risks excluding numerous essential care providers from network coverage, further destabilizing the health care safety net for low-income communities.
The Democratic caucus is urging HHS to reconsider these provisions, stressing that rolling back accessibility measures will undermine existing public health advancements while also increasing long-term costs for both patients and taxpayers. They contend that the emphasis should be on preserving and improving access to comprehensive health care services, particularly for vulnerable populations, rather than implementing restrictive policies that negatively affect women's health.
With these views firmly expressed, the Democratic Women's Caucus and Reproductive Freedom Caucus anticipate a reevaluation of the proposed rule CMS-9883-P to safeguard the interests of families and uphold the principles of the Affordable Care Act. They continue to advocate vigorously for health care policies that enhance access rather than limit it.
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The letter was signed by:
Teresa Leger Fernandez, Chair, Democratic Women's Caucus
Diana DeGette, Co-Chair, Reproductive Freedom Caucus
Ayanna Pressley, Co-Chair, Reproductive Freedom Caucus
Lizzie Fletcher, Vice Chair, Reproductive Freedom Caucus
Norma J. Torres, Vice Chair, Reproductive Freedom Caucus
Hillary J. Scholten, Vice Chair, Democratic Women's Caucus
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Read full text of letter here: https://www.regulations.gov/comment/CMS-2026-0496-1025
Md. Environment Dept. Opposes EPA's Proposed Interstate Transport Plan Review for 2015 Ozone Standards
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WASHINGTON, March 24 -- The Maryland Department of the Environment (MDE) has submitted a public comment letter to the U.S. Environmental Protection Agency expressing concerns about the agency's proposed Interstate Transport Plan Review for the 2015 Ozone National Ambient Air Quality Standard (NAAQS). MDE criticizes EPA's approach to approving State Implementation Plans (SIPs) for addressing interstate ozone pollution transport, particularly the agency's deviation from established frameworks and contribution thresholds.
MDE takes issue with EPA's departure from the long-standing four-step Interstate
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WASHINGTON, March 24 -- The Maryland Department of the Environment (MDE) has submitted a public comment letter to the U.S. Environmental Protection Agency expressing concerns about the agency's proposed Interstate Transport Plan Review for the 2015 Ozone National Ambient Air Quality Standard (NAAQS). MDE criticizes EPA's approach to approving State Implementation Plans (SIPs) for addressing interstate ozone pollution transport, particularly the agency's deviation from established frameworks and contribution thresholds.
MDE takes issue with EPA's departure from the long-standing four-step InterstateTransport Framework designed to assess and address upwind states' significant contributions to downwind ozone nonattainment and maintenance. The framework requires states to identify air quality problems, link emissions from upwind states, evaluate necessary emission reductions, and adopt enforceable measures. However, EPA's proposal allows approval of SIPs that recognize linkages but omit required analyses of emissions reductions and control programs. MDE describes this as arbitrary and capricious because it effectively permits linked states to avoid their obligations under the Clean Air Act (CAA).
Specifically, MDE highlights the cases of Kentucky and New Mexico, which identified linkages to downwind monitors but did not fully proceed with emissions reduction analyses as required. EPA's methodology favors deferring to state SIP content and selectively applying newer data to "de-link" states from downwind monitors, avoiding further regulatory steps. Maryland contends that Congress intended for upwind states to eliminate significant contributions without conditions related to downwind states' actions and that EPA's approach undermines the statutory intent.
MDE also opposes EPA's change in the contribution threshold used to determine significant interstate transport impacts. Whereas EPA proposes using a 1 part per billion (ppb) threshold, down from the historically applied 1% of the NAAQS standard, Maryland asserts that this weakens protections for downwind states. This shift could reduce accountability for upwind states while increasing local burdens on downwind areas. MDE emphasizes that the 1% threshold proportionally adjusts with the stringency of the NAAQS, maintaining consistent oversight. The department warns that higher thresholds, such as 2 ppb or 5% of the NAAQS, would further relax upwind state responsibilities and exacerbate air quality challenges.
MDE urges EPA to disapprove any SIPs that fail to comply fully with the four-step framework and to reject any increase in contribution thresholds that reduce interstate transport requirements. The department calls for adherence to the existing statutory timeline for SIP submissions and stresses the need to uphold the original purpose of the Good Neighbor provisions in the CAA. Maryland additionally endorses similar comments submitted by the Ozone Transport Commission under the same docket.
Through its letter, MDE underscores the importance of maintaining rigorous interstate pollution controls to protect public health and ensure progress in achieving and sustaining the 2015 ozone air quality standard nationwide.
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The letter was signed by:
Christopher R. Hoagland, Director
Air and Radiation Administration
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Read full text of letter here: https://www.regulations.gov/comment/EPA-HQ-OAR-2025-0192-0102
Koyuk Native Urges Careful Review of Federal Subsistence Management Program by Department of the Interior
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WASHINGTON, March 24 -- The Koyuk Native Corp., Alaska, has submitted a public comment letter to the U.S. Department of the Interior concerning the Federal Subsistence Management Program (Docket No. DOI-2025-0170). The organization expressed support for maintaining the core elements of the FSMP, which provides rural Alaskans, many of whom are Alaska Native, with a subsistence priority for fishing and hunting on federal lands and waters as established under Title VIII of the Alaska National Interest Lands Conservation Act (ANILCA).
The letter emphasizes the importance of conducting a thorough and
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WASHINGTON, March 24 -- The Koyuk Native Corp., Alaska, has submitted a public comment letter to the U.S. Department of the Interior concerning the Federal Subsistence Management Program (Docket No. DOI-2025-0170). The organization expressed support for maintaining the core elements of the FSMP, which provides rural Alaskans, many of whom are Alaska Native, with a subsistence priority for fishing and hunting on federal lands and waters as established under Title VIII of the Alaska National Interest Lands Conservation Act (ANILCA).
The letter emphasizes the importance of conducting a thorough andunhurried review of the program with inclusive consultations involving Alaska Native and rural communities, as well as formal consultations with Alaska Native Tribes. It underscores the legal and cultural necessity of the FSMP, which protects rural subsistence access that the state of Alaska cannot provide due to constitutional limitations. The corporation highlights that subsistence contributes critically to the economy and food security of rural Alaska, where replacing wild foods with market alternatives would be prohibitively expensive.
Koyuk Native Corporation advocates keeping the Office of Subsistence Management (OSM) within the Office of the Assistant Secretary for Policy, Management, and Budget of the Department of the Interior. The letter explains that OSM's current placement prioritizes subsistence concerns at high decision-making levels and avoids bureaucratic overhead that could reduce program effectiveness.
Moreover, the corporation strongly supports preserving the public seats on the Federal Subsistence Board, including tribally nominated members, as their firsthand knowledge of subsistence lifestyles is crucial for informed decision-making. The letter warns against deferring to the Alaska Department of Fish and Game, explaining that federal regulations provide the only enforceable rural preference under federal law, while state regulations treat all residents equally without rural priority.
The letter also calls for maintaining existing regional advisory council membership criteria that ensure local and subsistence users provide input grounded in traditional and ecological knowledge. It stresses preserving the board's authority to implement special actions during emergencies and to make rural determinations considering the unique and diverse conditions of Alaskan communities.
Overall, the Koyuk Native Corporation articulates the critical role of the FSMP in sustaining the cultural, economic, and food security needs of rural Alaskans and urges the Department of the Interior to protect the integrity and authority of the program in its review process.
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The letter was signed by:
President Morris Nassuk
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Read full text of letter here: https://www.regulations.gov/comment/DOI-2025-0170-1005
Indiana Reentry Corp. Offers Recommendations on Workforce Pell Grant Regulations
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WASHINGTON, March 24 -- Indiana Reentry Corp., Indianapolis, Indiana, have submitted a public comment letter to the U.S. Department of Education Office of Postsecondary Education addressing the proposed regulations for the Workforce Pell Grant program (Docket No. ED-2026-OPE-0133). The organization, which works with justice-impacted populations across six states in partnership with corrections departments and workforce boards, outlined several key technical recommendations to enhance the implementation and accessibility of Workforce Pell Grants.
IRC and Reentry OS emphasized strong support for
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WASHINGTON, March 24 -- Indiana Reentry Corp., Indianapolis, Indiana, have submitted a public comment letter to the U.S. Department of Education Office of Postsecondary Education addressing the proposed regulations for the Workforce Pell Grant program (Docket No. ED-2026-OPE-0133). The organization, which works with justice-impacted populations across six states in partnership with corrections departments and workforce boards, outlined several key technical recommendations to enhance the implementation and accessibility of Workforce Pell Grants.
IRC and Reentry OS emphasized strong support forthe department's goal to expand Pell Grant eligibility to short-term, employer-aligned workforce training programs-a shift that could profoundly improve employment outcomes for justice-impacted individuals facing the highest barriers to workforce participation. The letter highlighted challenges such individuals face, including occupational licensing restrictions, supervision-related employment barriers, and a lack of portable credential documentation, all of which the Workforce Pell program is designed to address.
Among their primary recommendations, the organization called for clarification and protection of the incarceration exclusion in the completion and placement rate calculations, urging the department to specify acceptable documentation standards such as prison custody records or state notification systems. They also recommended extending exclusions to individuals on parole or community supervision who face employment limitations. The letter further identified the need for data infrastructure support during the proposed three-year on-ramp period, especially for states lacking statewide longitudinal data systems, to prevent a compliance cliff when stricter data requirements take effect.
IRC urged that Governor approval processes include documented interagency data-sharing agreements essential for verifying program outcomes, and for recognition of private-sector workforce tracking platforms meeting federal data privacy standards as fulfilling data certification needs. The organization recommended an interim value-added earnings metric aligned with existing Workforce Innovation and Opportunity Act (WIOA) methodologies to provide accountability benchmarks before official calculations begin in 2030-31.
The letter also requested expanding automatic Governor approval to Department of Labor-designated pre-apprenticeship programs and recommended raising or modifying the 25% written arrangement cap that limits the role of community-based reentry organizations in delivering services. IRC stressed that these wraparound supports, such as coaching, employment navigation, and longitudinal tracking, are integral to successful workforce outcomes for returning citizens and should not be constrained by the cap.
In conclusion, IRC and Reentry OS expressed readiness to provide further operational data and technical guidance to facilitate effective Workforce Pell implementation. Their detailed recommendations focus on ensuring that justice-impacted populations can access and benefit from this critical federal education investment while maintaining rigorous program quality and data accountability.
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The letter was signed by:
Tammy Scudder
Founder, Indiana Reentry Corporation
Indiana Reentry Corporation
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Read full text of letter here: https://www.regulations.gov/comment/ED-2026-OPE-0133-0033
Hotel Council of San Francisco Supports Zoox Petition to NHTSA for Autonomous Vehicle Deployment
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WASHINGTON, March 24 -- The Hotel Council of San Francisco submitted a public comment letter to the National Highway Traffic Safety Administration voicing support for Zoox's petition (Docket No. NHTSA-2025-0523). The petition requests an exemption that would allow the commercial deployment of Zoox's automated vehicles under strict federal safety monitoring.
The letter emphasizes San Francisco's role as a major visitor destination and hub of innovation that requires safe and efficient mobility solutions to serve millions of residents, workers, and tourists annually. The council highlights autonomous
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WASHINGTON, March 24 -- The Hotel Council of San Francisco submitted a public comment letter to the National Highway Traffic Safety Administration voicing support for Zoox's petition (Docket No. NHTSA-2025-0523). The petition requests an exemption that would allow the commercial deployment of Zoox's automated vehicles under strict federal safety monitoring.
The letter emphasizes San Francisco's role as a major visitor destination and hub of innovation that requires safe and efficient mobility solutions to serve millions of residents, workers, and tourists annually. The council highlights autonomousvehicle technology as a transformative opportunity to improve both transportation safety and the city's economic health.
According to the organization, autonomous mobility could improve accessibility for visitors while reducing congestion and providing reliable and sustainable travel methods throughout San Francisco. It is also viewed as a means to open up more employment opportunities, strengthen connections within neighborhoods, and foster economic growth for local workers and businesses.
The council expressed strong backing for Zoox's ongoing collaboration with city agencies, safety advocates, and community stakeholders to ensure that autonomous mobility advances safety, equity, and opportunity for all people in the city. They believe that the successful roll-out of Zoox's services will not only enhance the transportation system but also bolster San Francisco's reputation as a leading destination for tourism, innovation, and sustainability.
In urging NHTSA to approve the temporary exemption outlined in the docket, the letter states that such a decision will promote safer roadways while stimulating economic progress, tourism, and innovation in San Francisco and beyond. The council asserts that authorized implementation of Zoox's automated vehicle technology aligns with the city's goals for a forward-looking and vibrant transportation landscape.
The National Highway Traffic Safety Administration's consideration of this petition comes at a time when several urban centers are assessing regulatory frameworks for integrating automated vehicle technologies safely into public roadways. The Hotel Council of San Francisco's support reflects a local industry's interest in leveraging new mobility solutions to enhance urban life and economic opportunities.
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The letter was signed by:
Alex Bastian
President & CEO
Hotel Council of San Francisco
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Read full text of letter here: https://www.regulations.gov/comment/NHTSA-2025-0523-0021
GrowSF Backs Zoox Petition for Autonomous Vehicle Deployment in San Francisco
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WASHINGTON, March 24 -- GrowSF submitted a public comment letter to the National Highway Traffic Safety Administration expressing support for Zoox's petition (Docket No. NHTSA-2025-0523), which requests an exemption to allow the commercial deployment of automated vehicles under federal safety monitoring.
The letter highlights San Francisco's reliance on safe and innovative transportation solutions to serve millions of residents, workers, and visitors annually. GrowSF believes autonomous vehicle (AV) technologies like those developed by Zoox could improve the city's mobility landscape by offering
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WASHINGTON, March 24 -- GrowSF submitted a public comment letter to the National Highway Traffic Safety Administration expressing support for Zoox's petition (Docket No. NHTSA-2025-0523), which requests an exemption to allow the commercial deployment of automated vehicles under federal safety monitoring.
The letter highlights San Francisco's reliance on safe and innovative transportation solutions to serve millions of residents, workers, and visitors annually. GrowSF believes autonomous vehicle (AV) technologies like those developed by Zoox could improve the city's mobility landscape by offeringmore reliable, predictable, and accessible transportation options. The organization sees AVs as a complement to existing transit systems that could help bridge first- and last-mile connectivity gaps, reduce traffic congestion through optimized routing, and expand transportation reach to underserved neighborhoods.
According to GrowSF, such improvements would facilitate easier travel across the city, aiding commuters, service industry workers, and visitors accessing commercial districts and essential services. The group also pointed to benefits for small businesses, restaurants, and retail corridors, which could see increased customer foot traffic as a result of enhanced transit access provided by AVs.
The letter further emphasizes that expanding dependable transportation options could particularly assist workers in service and hospitality sectors who often have nontraditional work hours. More predictable and safer commutes could bolster San Francisco's workforce and strengthen the local economy.
GrowSF noted San Francisco's history of embracing innovation and sees supporting regulated deployment of AVs as consistent with the city's commitment to progress and addressing urban challenges. The organization called for NHTSA's exemption approval as an important step toward fostering a transportation environment that is both more accessible and economically vibrant.
In conclusion, GrowSF expressed its strong support for the Zoox petition, underscoring the value of the company's autonomous vehicle technology under NHTSA's ongoing oversight for enhanced safety and mobility in San Francisco.
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The letter was signed by:
Sachin Agarwal and Steven Buss Bacio
Directors,
GrowSF
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Read full text of letter here: https://www.regulations.gov/comment/NHTSA-2025-0523-0023
American Water Supports EPA Compliance Deadline Extension for Hazardous Substance Reporting
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WASHINGTON, March 24 -- American Water Works Co. Inc., Camden, New Jersey, has submitted a public comment letter to the U.S. Environmental Protection Agency expressing support for the agency's proposal to extend the compliance deadline by three years for the Clean Water Act Hazardous Substance Facility Report Plans regulation (Docket No. EPA-HQ-OLEM-2021-0585).
American Water, a major water and wastewater service provider serving approximately 14 million people across 14 states, including over 300 public drinking water systems and about 200 wastewater treatment plants, urges the U.S. EPA to act
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WASHINGTON, March 24 -- American Water Works Co. Inc., Camden, New Jersey, has submitted a public comment letter to the U.S. Environmental Protection Agency expressing support for the agency's proposal to extend the compliance deadline by three years for the Clean Water Act Hazardous Substance Facility Report Plans regulation (Docket No. EPA-HQ-OLEM-2021-0585).
American Water, a major water and wastewater service provider serving approximately 14 million people across 14 states, including over 300 public drinking water systems and about 200 wastewater treatment plants, urges the U.S. EPA to actquickly on the extension. The company cited concerns that, without the extension, affected facilities would need to begin implementation of the current rule, incurring substantial costs that might become unnecessary if the rule is revised later. These tasks include initial modeling to determine potential impacts and development of response plans where needed.
The letter highlighted that American Water's operations also extend to providing services at 18 military installations through its Military Services Group, managing contracts under the U.S. Government's Utilities Privatization Program. Drawing on its experience, the company emphasized the strain water and wastewater systems face in balancing priorities such as lead service line replacement and PFAS testing and treatment while working under limited resources. The company argues that this context necessitates rule requirements grounded in sound science that deliver effective public health protection without imposing redundant administrative burdens.
American Water's correspondence appeals to the agency to use the proposed extension period to address implementation challenges and clarify regulatory requirements thoughtfully. Finalizing the extension, the letter contends, will prevent unnecessary expenditures ultimately borne by customers and provide the U.S. EPA sufficient time to revise the rule in a manner that serves communities effectively and efficiently.
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The letter was signed by:
Matthew Csik
Vice President, Water Quality and Compliance
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Read full text of letter here: https://www.regulations.gov/comment/EPA-HQ-OLEM-2021-0585-0407
American Veterinary Medical Association Submits Public Comment to USDA on Breeding Female Dog Care Standards
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WASHINGTON, March 24 -- The American Veterinary Medical Association (AVMA) submitted a public comment letter to the U.S. Department of Agriculture Animal and Plant Health Inspection Service (Docket No. APHIS-2025-1000). This docket solicits input on establishing standards for the care of breeding female dogs and the exercise and socialization of dogs governed by the Animal Welfare Act.
In its letter, the AVMA emphasized the challenge of applying a uniform care standard across diverse dog breeds, noting variations in size, maturity, litter size, and health risks. The association highlighted health
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WASHINGTON, March 24 -- The American Veterinary Medical Association (AVMA) submitted a public comment letter to the U.S. Department of Agriculture Animal and Plant Health Inspection Service (Docket No. APHIS-2025-1000). This docket solicits input on establishing standards for the care of breeding female dogs and the exercise and socialization of dogs governed by the Animal Welfare Act.
In its letter, the AVMA emphasized the challenge of applying a uniform care standard across diverse dog breeds, noting variations in size, maturity, litter size, and health risks. The association highlighted healthconcerns for breeding females related to transmissible venereal tumors and diseases such as brucella, canine leishmaniosis, and canine herpesvirus-1, along with complications linked to mating, pregnancy, whelping, and lactation. The letter encourages careful nutritional management during gestation, recommending commercially available diets labeled for reproduction or all life stages and veterinary-guided supplementation decisions.
The AVMA discussed the importance of assessing breeding age and genetic health. It advocated not breeding dogs before physical maturity and stressed testing for inherited disorders to inform breeding decisions and enhance long-term genetic health. The association urged consideration of breed-specific factors and veterinary interpretation of test results, including consultations with veterinary geneticists to balance breeding program objectives with genetic diversity preservation and gradual disease elimination.
Regarding the socialization and exercise of dogs, the letter cited scientific evidence supporting the welfare benefits of positive social interactions with humans and compatible dogs. It noted that social and exercise needs vary individually and depend on factors such as breed, age, health, and reproductive status. The AVMA recommended integrating activities like play, reward-based training, and leash walks in daily exercise plans and stressed the critical role of veterinary involvement in tailoring these plans to each dog's needs.
The AVMA encouraged flexibility within the USDA APHIS standards to improve animal welfare outcomes based on individual dog needs and veterinary guidance. The organization expressed readiness to engage further on enhancing breeding dog welfare through scientific research and pointed stakeholders to related AVMA resources for veterinarians on animal health and welfare.
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The letter was signed by:
Janet D. Donlin, DVM, CAE
Executive Vice President and Chief Executive Officer
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Read full text of letter here: https://www.regulations.gov/comment/APHIS-2025-1000-1295
Law Firm for Truck Safety Joins Opposition to Federation of Professional Truckers Electronic Logging Device Exemption Request
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WASHINGTON, March 22 -- The Law Firm for Truck Safety (TLFTS), Toledo, Ohio, submitted a public comment letter to the Federal Motor Carrier Safety Administration regarding an application from the Federation of Professional Truckers (FOPT) for exemption from the electronic logging device (ELD) requirements. TLFTS expressed strong opposition to the exemption, emphasizing the importance of the ELD mandate in reducing fatigued driving among commercial drivers.
In its letter, TLFTS highlighted the long-standing recognition by Congress that fatigued driving is a significant contributor to traffic-related
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WASHINGTON, March 22 -- The Law Firm for Truck Safety (TLFTS), Toledo, Ohio, submitted a public comment letter to the Federal Motor Carrier Safety Administration regarding an application from the Federation of Professional Truckers (FOPT) for exemption from the electronic logging device (ELD) requirements. TLFTS expressed strong opposition to the exemption, emphasizing the importance of the ELD mandate in reducing fatigued driving among commercial drivers.
In its letter, TLFTS highlighted the long-standing recognition by Congress that fatigued driving is a significant contributor to traffic-relateddeaths and injuries. The firm pointed out that the implementation of Hours of Service regulations began in 1937, with ongoing enforcement by both state troopers and the federal agency. The letter noted that the ELD requirement, established by Congress in 2012, addressed serious shortcomings associated with paper logbooks, which were often falsified, leading to safety hazards on the roads.
The organization expressed concern that granting FOPT's application could effectively dismantle the comprehensive ELD mandate created by Congress through the Moving Ahead for Progress in the 21st Century Act (MAP-21). TLFTS stated that allowing exemptions would negate the safety improvements recognized by a bipartisan consensus, undermining the efforts to combat fatigued driving.
The letter cited numerous instances of research and testimonies presented to Congress, which demonstrate the prevalence of hours-of-service violations documented during roadside inspections, underscoring the necessity for ELDs. TLFTS emphasized that electronic logging devices provide a superior alternative to paper logbooks, allowing law enforcement to effectively monitor compliance with safety regulations.
According to TLFTS, the exemptions sought by FOPT could lead to a severe regression in safety standards. The firm remarked that while ELDs are not exempt from problems, they offer transparency and reduce the potential for driver harassment, a concern expressly addressed in the legislation.
TLFTS concluded the letter by urging the federal agency to remain steadfast in its commitment to uphold the comprehensive ELD requirements, maintaining that straying from established safety protocols would endanger the public and contradict the intent of Congress. The firm stressed that the ELD system, despite limitations, continues to represent a crucial advancement in motor carrier safety and compliance enforcement.
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The letter was signed by:
The Law Firm for Truck Safety
Andy Young
Michael Leizerman
Matthew Wright
DJ Young
Joe Ervin
Grant Lawson
*
Read full text of letter here: https://www.regulations.gov/comment/FMCSA-2025-1282-0905
Transportation Trades Department Urges Caution on Buy America Proposal for EV Chargers
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WASHINGTON, March 22 -- The AFL-CIO Transportation Trades Department (TTD) has issued a public comment letter to the Federal Highway Administration expressing its position on the proposed modification of the Buy America requirements for electric vehicle chargers. The letter addresses a FHWA proposal to increase the domestic content threshold for components used in Federal-aid highway projects from 55 percent to potentially 100 percent.
As a prominent transportation labor federation in the United States, TTD advocates on behalf of unions whose members are involved in various transportation sectors,
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WASHINGTON, March 22 -- The AFL-CIO Transportation Trades Department (TTD) has issued a public comment letter to the Federal Highway Administration expressing its position on the proposed modification of the Buy America requirements for electric vehicle chargers. The letter addresses a FHWA proposal to increase the domestic content threshold for components used in Federal-aid highway projects from 55 percent to potentially 100 percent.
As a prominent transportation labor federation in the United States, TTD advocates on behalf of unions whose members are involved in various transportation sectors,including construction and manufacturing. The organization emphasizes the importance of linking a robust transportation system with a strong domestic manufacturing sector. In its letter, TTD highlighted concerns that any increase in domestic content requirements should be approached with caution to safeguard the manufacturing growth that the current Buy America policies have fostered.
TTD noted that the FHWA's phased approach to Buy America has already yielded positive outcomes, resulting in the establishment of several electric vehicle charging manufacturing facilities within the country. The organization asserts that the EV charger manufacturing sector is crucial for sustaining good union jobs and that growth in this area is essential. Thus, it advocates for a gradual adjustment to domestic content requirements, ensuring that such changes are market-informed and supported by consistent funding.
The organization cautioned that without a carefully designed strategy for increasing domestic content, the proposed modification could inadvertently hinder the manufacturing growth it aims to stimulate. TTD emphasized that while ambitious domestic content thresholds are important, they must align with current and projected market capabilities to be effective.
In light of the FHWA's proposal, TTD has expressed its eagerness to collaborate with the agency moving forward. The organization remains committed to advocating for policies that protect jobs while enhancing domestic manufacturing capacities, believing this balance is crucial for the ongoing development of the nation's infrastructure.
As authorities consider the implications of modifying Buy America requirements for electric vehicle chargers, the insights from TTD are set to play a significant role in shaping policy discussions and ensuring that the transition towards a more sustainable transportation infrastructure remains beneficial for the workforce and manufacturing sector alike.
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The letter was signed by:
Greg Regan
President
*
Read full text of letter here: https://www.regulations.gov/comment/FHWA-2025-0070-0096
Clifford Chance Proposes Enhancements to Committee on Foreign Investment in U.S. Known Investor Program and Review Procedures
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WASHINGTON, March 22 -- Clifford Chance US LLP, New York, submitted a public comment letter to the U.S. Department of the Treasury addressing the Committee on Foreign Investment in the U.S. (CFIUS) Known Investor Program (KIP) and opportunities to streamline the foreign investment review process. Drawing on its extensive experience advising clients on CFIUS matters, the law firm offered recommendations aimed at improving the efficiency and clarity of CFIUS operations while preserving the Committee's national security mission.
The letter notes that participating in the KIP requires significant
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WASHINGTON, March 22 -- Clifford Chance US LLP, New York, submitted a public comment letter to the U.S. Department of the Treasury addressing the Committee on Foreign Investment in the U.S. (CFIUS) Known Investor Program (KIP) and opportunities to streamline the foreign investment review process. Drawing on its extensive experience advising clients on CFIUS matters, the law firm offered recommendations aimed at improving the efficiency and clarity of CFIUS operations while preserving the Committee's national security mission.
The letter notes that participating in the KIP requires significantupfront disclosure and ongoing compliance efforts by eligible investors, with no guaranteed outcome in transaction reviews. To encourage broader participation, Clifford Chance suggests CFIUS clarify the practical benefits of KIP enrollment and consider incentives such as reduced or waived filing fees and easing information submission obligations like personal identifiers and professional synopses in filings. The firm also recommends annual public reporting on KIP-specific transaction data, processing times, and mitigation or blocking outcomes to provide transparency and assist investor decision-making.
Clifford Chance proposes exempting holding companies and special purpose vehicles (SPVs) that are wholly owned and controlled by KIP-approved entities from undergoing separate KIP vetting. The law firm argues this would reflect common transaction structures, streamline procedures, and enhance participation without compromising national security.
Regarding eligibility, the firm advocates for removing the current requirement that KIP applicants possess prior CFIUS filing history. This change could incentivize investors aiming to enter the U.S. market and complement broader government efforts to attract foreign investment, particularly in sectors linked to national security.
The letter also addresses process improvements. Clifford Chance recommends ending the informal prefiling review for declarations, which can extend timelines beyond regulatory expectations and complicate transaction planning. Instead, CFIUS should limit comments to clearly required information and consider setting a defined period for acceptance or feedback.
To reduce uncertainty, the firm advises that the Committee provide an acknowledgment at the conclusion of non-notified inquiries when no filing is requested, reserving future rights as needed. Enhancements to mitigation discussions are also suggested, including offering parties greater detail on identified risks and earlier engagement before drafting mitigation agreements. Inclusion of sunset clauses or periodic reviews in mitigation agreements is encouraged to adapt to evolving risk landscapes.
Furthermore, Clifford Chance calls for expanded guidance on voluntary filings to help parties better assess filing needs and support consistent decision-making. Simplifying the filing fee payment process by allowing wire transfers, akin to antitrust procedures, is recommended to remove administrative burdens and delays tied to the current portal and account requirements.
The firm's comprehensive suggestions aim to promote transparency, efficiency, and investor confidence in the CFIUS review system, balancing facilitation of foreign investment with safeguarding U.S. national security interests. The Treasury Department's consideration of these comments will shape the future implementation of the Known Investor Program and CFIUS processes.
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The letter was signed by:
CLIFFORD CHANCE US LLP
Karalyn D. Mildorf
Partner
+1 202 912 5083
karalyn.mildorf@cliffordchance.com
*
Renee A. Latour
Partner
+1 202 912 5509
renee.latour@cliffordchance.com
*
Read full text of letter here: https://www.regulations.gov/comment/TREAS-DO-2026-0067-0020
4 Government Groups Urge Census Bureau to Expand 2026 Test Scope
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WASHINGTON, March 21 -- The National League of Cities, along with the U.S. Conference of Mayors, the National Association of Counties, and the International City/County Management Association, submitted a public comment letter to the U.S. Department of Commerce raising concerns about the proposed 2026 Operational Test for the 2030 Census, warning that planned changes could weaken accuracy and increase long-term costs.
The NLC represents over 19,000 municipalities across the nation and, in collaboration with the United States Conference of Mayors, the National Association of Counties, and the International
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WASHINGTON, March 21 -- The National League of Cities, along with the U.S. Conference of Mayors, the National Association of Counties, and the International City/County Management Association, submitted a public comment letter to the U.S. Department of Commerce raising concerns about the proposed 2026 Operational Test for the 2030 Census, warning that planned changes could weaken accuracy and increase long-term costs.
The NLC represents over 19,000 municipalities across the nation and, in collaboration with the United States Conference of Mayors, the National Association of Counties, and the InternationalCity/County Management Association, has highlighted that the decennial census is vital for ensuring fair political representation and the proper allocation of federal resources. They point out that a comprehensive and accurate census is essential to serving governmental needs, business planning, and community services.
Among the concerns raised is the curtailment of the 2026 test sites, which the organizations argue will lead to shortcomings in testing new methodologies and technologies. The letter stresses that robust mid-decade testing, as seen in previous census cycles, is crucial for addressing potential issues before they escalate into costly errors.
Notably, the organizations criticize the decision to limit test sites to only two locations: Spartanburg, South Carolina, and Huntsville, Alabama. This reduction diminishes the representation of historically hard-to-count populations in varied geographic areas, including rural and tribal regions that were inadequately represented in the 2020 Census.
The letter also addresses modifications to how in-field enumeration will be conducted, raising apprehensions that reliance on United States Postal Service workers may exclude certain difficult-to-enumerate locations. These changes could further exacerbate deficiencies highlighted by previous census efforts. Moreover, the importance of making testing materials available in multiple languages-a practice supported in past census efforts-is reiterated as a vital strategy for inclusivity.
In light of these concerns, the NLC and its partners have urged the Census Bureau to reconsider the cancellation of four test sites, restore focus on the Group Quarters component, and use the decennial questionnaire as originally mandated. They caution that failing to implement these recommendations could lead to increased costs and challenges in executing a successful 2030 decennial census. The call to action aims not only to enhance census accuracy but also to protect the integrity of the population count that shapes federal policy and funding for years to come.
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The letter was signed by:
Clarence Anthony, CEO and Executive Director, National League of Cities
Tom Cochran, CEO and Executive Director, The United States Conference of Mayors
Matthew D. Chase, Executive Director/CEO, National Association of Counties (NACo)
Julia D. Novak, CEO/Executive Director, International City/County Management Association
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Read full text of letter here: https://www.regulations.gov/comment/USBC-2026-0034-0112
6 Recreational Groups Urge Commerce Department to Approve State Red Snapper Pilot Programs
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WASHINGTON, March 21 -- A coalition of 6 recreational fishing and marine industry organizations submitted a public comment letter to the U.S. Department of Commerce urging approval of state-led exempted fishing permit applications for Atlantic red snapper, arguing the proposals would expand angler access while maintaining conservation standards.
According to the letter, recreational access has become increasingly restricted, with federal fishing seasons measured in mere days, such as the two-day season implemented in 2025. This situation stands in contrast to the observed abundance of red snapper
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WASHINGTON, March 21 -- A coalition of 6 recreational fishing and marine industry organizations submitted a public comment letter to the U.S. Department of Commerce urging approval of state-led exempted fishing permit applications for Atlantic red snapper, arguing the proposals would expand angler access while maintaining conservation standards.
According to the letter, recreational access has become increasingly restricted, with federal fishing seasons measured in mere days, such as the two-day season implemented in 2025. This situation stands in contrast to the observed abundance of red snapperin the waters, leading to frustration among anglers and diminishing their faith in federal management measures.
The letter outlines that for nearly two decades, the management strategies for South Atlantic red snapper have lagged behind the fishery's recovery, with federal responses often resulting in tighter restrictions rather than acknowledging the increasing stock health. The proposed EFPs from the four states are positioned as a viable solution, offering practical pathways tailored to each state's management needs.
Each state's EFP application reflects its unique circumstances, with Florida leveraging its extensive experience in managing snapper fisheries, Georgia focusing on stakeholder collaboration, South Carolina implementing science-driven frameworks, and North Carolina addressing the diverse interests of both recreational and charter sectors. This coordinated approach highlights the benefits of cooperative federalism, allowing states to experiment with management tools that align with local conditions.
The letter emphasizes the significance of the Modern Fish Act, signed into law by President Trump in 2018, which empowers the National Oceanic and Atmospheric Administration (NOAA) to manage recreational fisheries through alternative measures apart from traditional catch limits. The EFPs would maintain conservation measures while enabling states to utilize enhanced data collection and management practices tailored to their fisheries.
If approved, the EFPs would facilitate extended recreational fishing seasons in 2026, varying from 39 to 62 days based on state contributions. The letter underscores the essential role recreational fishing plays in the cultural and economic wellbeing of communities across the South Atlantic.
The organization urges the Department of Commerce to promptly approve the EFP applications and continue close collaboration with NOAA Fisheries and state agencies to realize these important pilot programs. The call for action is clear, as stakeholders prioritize adapting management tools to match both conservation successes and the intent of Congress.
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The letter was signed by:
Heather Lougheed, President
BoatU.S.
*
Jeff Angers, President
Center for Sportfishing Policy
*
Jeff Crane, President
Congressional Sportsmen's Foundation
*
Dr. Guy Harvey, Founder and Chair Emeritus
Guy Harvey Foundation
*
Jason Schratwieser, President
International Game Fish Association
*
Frank Hugelmeyer, President
National Marine Manufacturers Association
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Read full text of letter here: https://www.regulations.gov/comment/NOAA-NMFS-2026-0496-11065
23 A.G. Coalition Support HHS Proposal Clarifying Disability Definition Under Section 504
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WASHINGTON, March 21 -- A coalition of 23 state attorneys general have submitted a public comment letter to the U.S. Department of Health and Human Services in response to the agency's Notice of Proposed Rulemaking on nondiscrimination regarding individuals with disabilities. The letter emphasizes their support for the proposed changes that seek to clarify the definition of disability under Section 504 of the Rehabilitation Act.
The proposed revisions aim to exclude "gender identity disorders not resulting from physical impairments" from the definition of disability, as stipulated in the Rehabilitation
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WASHINGTON, March 21 -- A coalition of 23 state attorneys general have submitted a public comment letter to the U.S. Department of Health and Human Services in response to the agency's Notice of Proposed Rulemaking on nondiscrimination regarding individuals with disabilities. The letter emphasizes their support for the proposed changes that seek to clarify the definition of disability under Section 504 of the Rehabilitation Act.
The proposed revisions aim to exclude "gender identity disorders not resulting from physical impairments" from the definition of disability, as stipulated in the RehabilitationAct. The current regulations, dating back to a rule implemented by the previous administration, extended the definition to include conditions like gender dysphoria, which the attorneys general argue contradicts federal law. The letter contends that these expansions threaten state authority and create potential liabilities for states that do not comply with the broadened definition.
The letter highlights concerns that the 2024 Final Rule, which recognizes gender dysphoria as a permissible disability, is misaligned with congressional intent and statutory exclusions set forth in the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The attorneys general assert this broadening of the definition could result in states facing enforcement actions, litigation, and loss of federal funding due to alleged noncompliance with the rule.
Attorneys general from Texas, Alabama, Alaska, and numerous other states represented in the letter stress that misinterpretations of federal law could lead to severe ramifications in the enforcement of state legislation, particularly concerning child welfare and employment policies. The proposed amendments to Section 504 are viewed as crucial to maintaining the integrity of state-run programs while reducing the risk of legal challenges based on subjective conditions.
They urge the agency to finalize the Notice of Proposed Rulemaking, citing that doing so would provide clarity on the disabilities recognized under federal law and prevent exploitation of disability accommodations related specifically to gender dysphoria. The collective voice of these state attorneys general underscores the ongoing debate about the intersection of disability rights, gender identity, and state authority in the implementation of federal programs.
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The letter was signed by:
Ken Paxton, Attorney General of Texas
Steve Marshall, Attorney General of Alabama
Lynn Fitch, Attorney General of Mississippi
Stephen J. Cox, Attorney General of Alaska
Austin Knudsen, Attorney General of Montana
Tim Griffin, Attorney General of Arkansas
Mike Hilgers, Attorney General of Nebraska
James Uthmeier, Attorney General of Florida
Drew H. Wrigley, Attorney General of North Dakota
Chris Carr, Attorney General of Georgia
Dave Yost, Attorney General of Ohio
Raul R. Labrador, Attorney General of Idaho
Gentner Drummond, Attorney General of Oklahoma
Todd Rokita, Attorney General of Indiana
Alan Wilson, Attorney General of South Carolina
Brenna Bird, Attorney General of Iowa
Marty Jackley, Attorney General of South Dakota
Kris W. Kobach, Attorney General of Kansas
Derek Brown, Attorney General of Utah
Russell Coleman, Attorney General of Kentucky
John B. McCuskey, Attorney General of West Virginia
Liz Murrill, Attorney General of Louisiana
Keith G. Kautz, Attorney General of Wyoming
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Read full text of letter here: https://www.regulations.gov/comment/HHS-OCR-2026-0034-0367
20 Attorneys General Call on Census Bureau to Reverse Course on 2026 Operational Test
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WASHINGTON, March 21 -- A coalition of 20 state attorneys general submitted a public comment letter to the U.S. Census Bureau expressing their opposition to proposed changes for the 2026 Operational Test, which is intended to support plans for the 2030 Census. The group argues that the adjustments threaten to undermine the accuracy and integrity of future census counts, particularly among historically undercounted populations.
The comment letter addresses multiple issues raised by the Census Bureau's Notice, published in the Federal Register, which outlines significant modifications to the testing
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WASHINGTON, March 21 -- A coalition of 20 state attorneys general submitted a public comment letter to the U.S. Census Bureau expressing their opposition to proposed changes for the 2026 Operational Test, which is intended to support plans for the 2030 Census. The group argues that the adjustments threaten to undermine the accuracy and integrity of future census counts, particularly among historically undercounted populations.
The comment letter addresses multiple issues raised by the Census Bureau's Notice, published in the Federal Register, which outlines significant modifications to the testingprocedures. Among the most contentious of these changes is the proposal to incorporate the American Community Survey (ACS) questionnaire into the 2026 Test. The coalition argues that the ACS is not an appropriate substitute for the decennial census questionnaire and that its inclusion of a citizenship question is likely to depress response rates among immigrant and minority communities. These alterations could lead to a census that fails to reflect the true demographics of the nation, subsequently impacting federal resources and congressional representation.
The coalition also highlights procedural deficiencies in the Notice, asserting that it does not align with requirements under the Administrative Procedure Act. They argue that the Census Bureau's decision to label the changes as a notice rather than a proposed rule circumvents necessary public comment opportunities that would allow concerned parties to express their views and substantiate their objections.
Moreover, the attorneys general have raised alarms over the Bureau's plan to reduce the number of test sites from six to two, which they believe will limit the test's effectiveness in assessing the operational changes needed to reach the hardest-to-count populations. The two selected locations-Spartanburg, South Carolina, and Huntsville, Alabama-are criticized for not adequately representing diverse communities that the Census Bureau aims to include in future counts.
"Without adequate testing in areas with significant Hispanic and immigrant populations, we risk repeating past mistakes that contributed to undercounts in these communities," said a spokesperson for the coalition. The letter urges the Census Bureau to revert to its original testing criteria, including maintaining a robust number of diverse test sites and using the established census questionnaire for effective planning for the 2030 Census.
As the nation prepares for this critical count, the attorneys general emphasize that a fair and accurate census is vital to democracy, urging the Bureau to address these concerns seriously and comprehensively. Their letter serves as a rallying cry for the protection of marginalized voices in the counting process.
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The letter was signed by:
Letitia James, Attorney General of New York
Jennifer Davenport, Attorney General of New Jersey
Rob Bonta, Attorney General of California
Phil Weiser, Attorney General of Colorado
William Tong, Attorney General of Connecticut
Kathleen Jennings, Attorney General of Delaware
Brian Schwalb, Attorney General for the District of Columbia
Anne E. Lopez, Attorney General of Hawai'i
Kwame Raoul, Attorney General of Illinois
Aaron M. Frey, Attorney General of Maine
Anthony G. Brown, Attorney General of Maryland
Andrea Joy Campbell, Attorney General of Massachusetts
Dana Nessel, Attorney General of Michigan
Keith Ellison, Attorney General of Minnesota
Aaron D. Ford, Attorney General of Nevada
Raul Torrez, Attorney General of New Mexico
Dan Rayfield, Attorney General of Oregon
Peter Neronha, Attorney General of Rhode Island
Charity R. Clark, Attorney General of Vermont
Nicholas W. Brown, Attorney General of Washington
Joshua L. Kaul, Attorney General of Wisconsin
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Read full text of letter here: https://www.regulations.gov/comment/USBC-2026-0034-0109
10 Advocacy Groups Urge HHS to Withdraw Proposed Rule on Gender Dysphoria and Section 504
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WASHINGTON, March 21 -- A coalition of 10 advocacy organizations submitted a public comment letter to the U.S. Department of Health and Human Services urging withdrawal of a proposed rule addressing disability protections under Section 504 of the Rehabilitation Act.
The AAPD, which represents over 70 million Americans with disabilities, emphasizes that the foundational principles of disability rights are enshrined in Section 504 of the Rehabilitation Act of 1973. According to the organization, this section bars discrimination against individuals with disabilities in federally-funded programs,
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WASHINGTON, March 21 -- A coalition of 10 advocacy organizations submitted a public comment letter to the U.S. Department of Health and Human Services urging withdrawal of a proposed rule addressing disability protections under Section 504 of the Rehabilitation Act.
The AAPD, which represents over 70 million Americans with disabilities, emphasizes that the foundational principles of disability rights are enshrined in Section 504 of the Rehabilitation Act of 1973. According to the organization, this section bars discrimination against individuals with disabilities in federally-funded programs,and should thus be interpreted broadly to include conditions like gender dysphoria. The advocacy groups contend that the proposed regulations risk limiting the protective scope of this statute, something that runs counter to historical legislative commitments.
Moreover, the letter highlights the integral relationship between Section 504 and other significant measures such as the Americans with Disabilities Act of 1990 (ADA) and its amendments. By possibly narrowing the definition of disability, HHS is allegedly undermining a critical safety net that has evolved over five decades to ensure comprehensive civil rights for individuals with disabilities, particularly in the context of health services.
The proposal's reinterpretation of terms related to gender identity disorders has sparked particular concern. The organizations argue that the proposed language neglects a crucial court ruling in the Fourth Circuit case of Williams v. Kincaid, which recognized gender dysphoria as a disability under existing laws. This ruling, they assert, obligates the department to uphold protections for individuals facing discrimination due to gender dysphoria and to initiate further clarity on the issue, rather than potentially endorsing discriminatory practices.
In addition, the letter points out that the current proposed rules have no verifiable instances of confusion warranting a revision of existing regulations. The organizations believe that rescinding the comprehensive updates to regulations would effectively dismantle important nondiscrimination protections that have been in place for decades, amplifying the call for HHS to reconsider any moves towards retraction.
The AAPD, along with the other organizations supporting the comment, urges HHS to ensure that any forthcoming regulations prioritize and protect the rights of individuals with disabilities, anchoring the discourse on inclusivity and equal opportunity that has historically been central to the disability rights movement.
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The letter was signed by:
American Association of People with Disabilities
Access Living
Boston Center for Independent Living
Caring Across Generations
Endependence center of Northern virginia
New Disabled South
The Julian Way
The Partnership for Inclusive Disaster Strategies
United Church of Christ
United Spinal Association
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Read full text of letter here: https://www.regulations.gov/comment/HHS-OCR-2026-0034-0357
