HFMA periodically issues comment letters to agencies such as the Centers for Medicare & Medicaid Services, the Internal Revenue Service, FASB and GASB, and other regulatory, legislative, and similar entities.

Our comment letters submitted since 2012 are listed below and organized by topic.

If you're looking for a comment letter issued prior to 2012, please contact us.

501r/Tax-Exempt Status

Accounting Guidance

Compliance / Fraud & Abuse


Health Insurance Exchanges



Medicare ACOs/MSSP/Pioneer

Medicare Bundled Payments

Medicare Payment Policy


Quality / Clinical

RAC/Short Stay Payments/Two-Midnight

Physician Fee Schedule