| Course | HA 610 Health Policy and Management |
|---|---|
| Unit | Unit 5 |
| Paper type | Public comment letter |
| Length | About 770 words, 5 pages |
| Format | APA 7 student paper |
| School | Herzing University |
| Program | MS in Healthcare Administration |
| Updated | October 2026 |
Free sample paper for HA 610 Unit 5
Comment on File Code CMS-1834-P: A Community Hospital's Letter on the Proposed Hospital Price Transparency Changes for Calendar Year 2026
Student Name
Health Care Administration, Herzing University
HA 610: Health Policy and Management
Instructor Name
February 13, 2026
Comment on File Code CMS-1834-P: A Community Hospital's Letter on the Proposed Hospital Price Transparency Changes for Calendar Year 2026
Header
Submitted electronically via Regulations.gov. Date: September 10, 2025. To: Administrator, Centers for Medicare & Medicaid Services, Department of Health and Human Services. Re: File code CMS-1834-P, the calendar year 2026 outpatient and ambulatory surgical center proposed rule, including its hospital price transparency provisions, published in the Federal Register on July 17, 2025, at 90 FR 33476 (Centers for Medicare & Medicaid Services [CMS], 2025a). This letter addresses only the hospital price transparency provisions, which would amend 45 CFR Part 180. This is prepared for the course as the letter the composite hospital would have filed before the comment deadline; CMS later finalized the rule.
About the Commenter
[Composite] Community Hospital is a 180-bed nonprofit acute-care hospital serving about 110,000 residents of a mixed rural and small-city county. We have published a machine-readable file and a consumer price estimator since January 2021 and have updated both with each change to 45 CFR Part 180 since the original rule took effect (CMS, 2019). We hold fourteen commercial payer contracts; in five of them, some services are reimbursed at a set share of our list price, which is the situation several of the proposed changes address. Our comments come from direct experience of building and maintaining these files with a small analytics team.
Comment 1: Percentile Allowed Amounts for Percentage-Based Charges
Provision: the proposal that, where a payer-specific negotiated charge is expressed as a percentage or algorithm, hospitals add to the file the middle value of what was actually paid, the values at the low and high ends of the range, and how many payments those figures rest on.
Position: we support the proposal. A patient or employer cannot compare one hospital's percentage of billed charges with another's; a median allowed amount from actual payments is far more useful.
Evidence: when we tested this calculation on our own remittance data for one of our five percentage-based contracts, the median allowed amount for an outpatient MRI differed from the percentage applied to our list price by less than 3%, but the 10th to 90th percentile range was wide because of bundling differences. Posting the range will show purchasers something real.
Request: that CMS publish technical guidance with worked examples before the effective date, including how to handle services with very few payments in the look-back period, where a percentile is statistically meaningless.
Comment 2: The Source and Period of the Data
Provision: the proposal that these amounts come from the payment records insurers send hospitals, or an equivalent source, over a defined look-back period.
Position: we support using remittance data, which hospitals hold and can defend.
Evidence: remittance data include payments later adjusted by appeals or recoupments. In our test, about 4% of remittances for the tested contract were later adjusted.
Request: that CMS state whether adjusted payments should be included at their final value, and that the look-back period end at least 90 days before posting, to allow adjustments to settle.
Comment 3: Attestation by a Named Official
Provision: the proposal to replace the current affirmation with an attestation of completeness and accuracy that names a senior official.
Position: we support clear accountability and will comply. We ask for clarity on its scope.
Request: that CMS confirm that the attestation covers good-faith completeness and accuracy based on the hospital's records and methods at the time of posting, and that a hospital which identifies and corrects an error promptly will be treated as acting in good faith. Without that clarity, the attestation may discourage smaller hospitals from posting anything beyond the minimum.
Comment 4: Timing
Request: that enforcement of the new data elements begin no earlier than 90 days after the effective date, to allow hospitals to build and test the calculation after final guidance is issued. Studies of the original rule found that compliance lagged most among smaller and independent hospitals with less information technology capacity (Jiang et al., 2022); a short delay would help those hospitals comply accurately rather than hurriedly.
Thank you for the opportunity to comment. [Name], Vice President, Finance, on behalf of [Composite] Community Hospital.
Note on What Followed
In the final rule published in November 2025, CMS required the median and percentile allowed amounts, set the data window at between a year and fifteen months, adopted the named attestation, and delayed enforcement of the new data elements to April 1, 2026 (CMS, 2025b). The timing request in Comment 4 was, in effect, met. This note is added for the course and would not appear in the submitted letter.
References
Centers for Medicare & Medicaid Services. (2019). Medicare and Medicaid programs: CY 2020 hospital outpatient PPS policy changes and payment rates and ambulatory surgical center payment system policy changes and payment rates. Price transparency requirements for hospitals to make standard charges public. Federal Register, 84, 65524. https://www.federalregister.gov/d/2019-24931
Centers for Medicare & Medicaid Services. (2025a). Medicare and Medicaid programs: Hospital outpatient prospective payment and ambulatory surgical center payment systems; quality reporting programs; overall hospital quality star ratings; and hospital price transparency [Proposed rule]. Federal Register, 90, 33476. https://www.federalregister.gov/d/2025-13360
Centers for Medicare & Medicaid Services. (2025b). Medicare program: Hospital outpatient prospective payment and ambulatory surgical center payment systems; quality reporting programs; overall hospital quality star rating; hospital price transparency; and notice of closure of a teaching hospital and opportunity to apply for available slots. Federal Register, 90, 53448. https://www.federalregister.gov/d/2025-20907
Jiang, J. X., Polsky, D., Littlejohn, J., Wang, Y., Zare, H., & Bai, G. (2022). Factors associated with compliance to the hospital price transparency final rule: A national landscape study. Journal of General Internal Medicine, 37(14), 3577-3584. https://doi.org/10.1007/s11606-021-07237-y
Reading the HA 610 Unit 5 instructions
Unit 5 asks you to write a public comment letter on a proposed federal rule. Expect to identify the rule and docket, introduce the commenter, comment on specific provisions with evidence and requests, and keep a professional tone. Students often ask how formal the letter should be and how many comments to include. Use the file code and docket number, and address the agency administrator. Three to five comments on specific provisions are more useful than general support or opposition. Each comment should name the provision, state your view, give evidence and make a specific request. Agencies weigh substance, not volume, so data from your organization strengthens the letter.
How the HA 610 Unit 5 example is put together
The letter opens with a header giving the submission route, date, addressee and file code. The commenter section establishes who the hospital is and why its view matters. Four comment sections each follow the same structure: provision, position, evidence and request. The first comment supports the provision while asking for clarity. The second explains data timing challenges. The third proposes a practical attestation approach. The fourth asks for an enforcement grace period. The note at the end compares the requests with what CMS finalized. The letter is courteous, specific and evidence-based, the qualities agencies respond to. Each request is short enough that an agency reviewer could quote it in the preamble of a final rule.
Where the points sit in the HA 610 Unit 5 rubric
Herzing's rubric for a public comment letter usually covers rule identification, commenter description, specificity of comments, evidence, requests and professional tone. Specific comments with concrete requests carry the most weight, because agencies respond to suggestions tied to particular provisions rather than general opinions. Identification points reward the file code and docket number. Commenter criteria look for background that explains why the organization's view matters. Evidence earns credit when local data, such as the number of affected contracts, support each comment. Requests should be actionable, such as a set grace period. Tone points go to courteous, formal writing. The closing note comparing requests with the final rule is often credited. The CMS proposed rule CMS-1834-P and its final version anchor the letter.
HA 610 Unit 5 help: mistakes that cost points
Comment letters in HA 610 Unit 5 often slip by expressing general support or opposition without addressing specific provisions. Another frequent problem is missing the file code or docket number. Students often omit evidence from their own organization. Requests are vague, such as please reconsider. The tone becomes argumentative or sarcastic, which agencies discount. Too many comments dilute the letter. The commenter is not introduced, so the agency cannot judge relevance. The submission date falls outside the comment period. Comments repeat the same point under different headings. Finally, tie each comment to a provision and a request, because graders reward a letter an agency could actually use.
Get a HA 610 Unit 5 example written to your instructions
Send the Unit 5 instructions and the rubric from your HA 610 classroom, plus the proposed rule and the organization your letter writes on behalf of. We write a custom example with the docket identified, standing established and each comment carrying alternative language, and return it in 24 to 48 hours. The first custom sample is free.
More HA 610 papers and healthcare administration samples
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- HA 610 Unit 3: Regulatory impact memo
- HA 610 Unit 4: Stakeholder position paper
- HA 610 Unit 6: Testimony statement
- HA 610 Unit 7: Advocacy plan
- HA 610 Unit 8: Policy recommendation memo
- HA 630 Unit 5: Marketing mix and referral plan
- HA 635 Unit 5: Compensation structure review
- HA 640 Unit 5: Make or buy analysis
- HA 645 Unit 5: Quality improvement analysis
HA 610 Unit 5 questions, answered
Does the comment period have to be open?
Look at your instructions, since some sections require an open period and others accept a closed one. An open period lets you check the docket and read what other organizations filed, which sharpens your own submission. A closed one has the advantage that the final rule exists, so you can compare your recommendations against what the agency actually did with them.
How long should a comment letter run?
As long as the provisions you address require, and no longer. Agencies read for substance rather than volume, and a short letter addressing three provisions with evidence and proposed language carries more weight than a long one restating the rule. Follow whatever range your classroom sets, and give each comment the same internal structure so an analyst can move through them quickly.
Should the letter be written for my own employer?
Only where your classroom permits it, and then with confidential detail stripped out. A described organization works just as well: state the type, the size, the payer profile and the services, then keep those facts consistent. What gives a comment its weight is the operational evidence, and that can be stated at the level of process and volume without naming the institution.
Where can I find a free HA 610 Unit 5 sample paper?
The full HA 610 Unit 5 public comment letter is free on this page, four comments on CMS-1834-P with evidence and requests. A letter on another proposed rule can be prepared on request.
How do I write a public comment on a CMS proposed rule?
Cite the file code, introduce your organization, address specific provisions one at a time with evidence and a concrete request, and keep a professional tone. This sample comments on four price transparency provisions.