FDA Remanufacturing RFI, January 2019
CHI urged the FDA to categorize the service and repair of medical devices as a service, not as remanufacturing.
HIPAA, February 2019
CHI, in coordination with Dignity Health as part of the newly formed CommonSpirit Health, made recommendations to the Office of Civil Rights within the Department of Health and Human Services on ways to improve the Health Insurance Portability and Accountability Act (HIPAA).
Drug Rebates, April 2019
CHI, in coordination with Dignity Health as part of Common Spirit Health, made recommendations in the administration’s continued efforts to lower prescription drug prices for Medicare beneficiaries and other consumers. While we support the intent of the agency’s goals to lower drug prices, we were concerned that the proposed rule fails to address high drug prices or the structure that incentivizes use of brand-name drugs; the effects on Medicare beneficiaries are unclear, with experts leaning toward a negative impact; the proposal fails to hold drug manufacturers accountable for high drug prices; and the effective date is exceedingly impractical.