UPH Government & External Affairs

Regulatory Update – April 2022

by | Apr 25, 2022

UnityPoint Health has submitted comments letters in response to multiple state and federal agency proposals listed below. Click the links to learn more about our comment letters as well as agency proposed rules.



DHS: Community Mental Health Centers & Integrated Chronic Health Homes Amendments

Agency: Iowa Department of Human Services
Published: February 23, 2022
Submitted: March 15, 2022

Iowa DHS is requesting comments on proposed rule making related to Community Mental Health Centers (ARC 6211C) & Integrated and Chronic Health Homes (ARC 6206C).




WI GOV: Enactment of SB 259 Genetic Counseling Licensure

Agency: Wisconsin Governor Tony Evers
Letter Sent: March 10, 2022

UnityPoint Health Meriter, in partnership with UW Health, encourages Governor Tony Evers to sign SB 259 (licensure of genetic counselors) into law.




OSHA: Occupational Exposure to COVID-19; ETS – Additional Comments

Agency: Occupational Safety and Health Administration (OSHA)
Published: March 23, 2022
Submitted: April 22, 2022

OSHA is requesting additional information regarding the need for, and impact of the potential provisions and approaches specified in the ETS as well as additional studies, information and data related to the delta and omicron variants since the close of OSHA’s initial comment period in August 2021.

CDC: Clinical Practice Guideline for Prescribing Opioids

Agency: Centers for Disease Control and Prevention (CDC)
Published: February 10, 2022
Submitted: April 11, 2022

The CDC is requesting information on the 2022 Clinical Practice Guidelines for Prescribing Opioids.

ONC: Electronic Prior Authorization

Agency: Office of the National Coordinator for Health Information Technology (ONC)
Published: January 24, 2022
Submitted: March 25, 2022

ONC is requesting information on electronic prior authorization standards, implementation specifications, and certification criteria.

CMS: CY 2023 MA and Part D Benefit Programs

Agency: Centers for Medicare & Medicaid Services (CMS)
Published: January 12, 2022
Submitted: March 7, 2022

CMS is requesting comments on contract year 2023 proposed changes for MA and Part D.

DOJ & FTC’s Request for Information on Merger Enforcement

Lead Organization: The Academy Advisors (TAA)
Audience: Department of Justice and Federal Trade Commission

A sign-on letter dated April 19, 2022 was submitted by TAA on behalf of members in response to the DOJ and FTC’s request of information on merger enforcement.



The UnityPoint Health Government and External Affairs team is actively partnering with operational leaders on the following annual proposals currently open for comment:



The Government & External Affairs team works with subject matter experts from across UnityPoint Health to review these proposed regulations and provide formal input on behalf of the system. For transparency and awareness, past UnityPoint Health comment letters are accessible on the Government & External Affairs webpage.

For more information on the CMS rule making process or if you would like to participate as a UnityPoint Health content expert, please contact Cathy Simmons, executive director of government & external affairs for UnityPoint Health or Stephanie Collingwood, government relations specialist for UnityPoint Health