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Health Care Week in Review June 16, 2023


HEALTH CARE WEEK IN REVIEW: HHS COVERAGE FLEXIBILITIES AND MEDPAC/MACPAC REPORTS

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Below is Alston & Bird’s Health Care Week in Review, which provides a synopsis
of the latest news in health care regulations, notices, and guidance; federal
legislation and congressional committee action; reports, studies, and analyses;
and other health policy news.

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WEEK IN REVIEW HIGHLIGHT OF THE WEEK:

This week, the COVID-19 PHE expired, and DEA issued a final rule that provides a
six-month extension of PHE flexibilities that allow the prescription of
controlled substances via telemedicine.

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I. Regulations, Notices & Guidance

 * On June 13, 2023, the Agency for Healthcare Research and Quality (AHRQ)
   issued notices entitled, Supplemental Evidence and Data Request: Evaluation
   of Dietary Protein Intake Requirements and The Effect of Protein Intake on
   Health. AHRQ is seeking scientific information submissions from the public to
   inform its review on Evaluation of Dietary Protein Intake Requirements, which
   is currently being conducted by the AHRQ’s Evidence-based Practice Centers
   (EPC) Program. Access to published and unpublished pertinent scientific
   information is intended to improve the quality of this review. Information
   must be submitted by July 14, 2023.
 * On June 13, 2023, the Food and Drug Administration (FDA) issued final
   guidance entitled, Content of Premarket Submissions for Device Software
   Functions. This guidance document is intended to provide information
   regarding the recommended documentation sponsors should include in premarket
   submissions for FDA’s evaluation of safety and effectiveness of device
   software functions, which are functions that meet the definition of a device
   under the Federal Food, Drug, and Cosmetic Act (FD&C Act). This document
   replaces FDA’s “Guidance for the Content of Premarket Submissions for
   Software Contained in Medical Devices” issued on May 11, 2005, and updates
   FDA’s thinking related to the documentation FDA recommends sponsors include
   for the review of device software functions in premarket submissions.
 * On June 14, 2023, FDA extended the comment period for draft guidance
   entitled, Questions and Answers About Dietary Guidance Statements in Food
   Labeling: Draft Guidance for Industry. FDA is taking this action in response
   to requests for an extension to allow interested persons additional time to
   submit comments. The draft guidance, when finalized, will provide FDA’s
   current thinking on the use of Dietary Guidance Statements on packaged food
   labels and more broadly in the labeling of foods, including any written,
   printed, or graphic material accompanying a food, such as labeling on
   websites. This draft guidance is not final nor is it in effect at this time.
 * On June 15, 2023, the Department of Health and Human Services (HHS) issued
   draft guidance entitled, Frequently Asked Questions: Limited Institutional
   Review Board Review and Related Exemptions. This draft guidance document
   applies to research activities involving human subjects that are conducted or
   supported by HHS. It is intended primarily to help entities implement the
   requirement for limited review of research by an Institutional Review Board
   (IRB) to meet the conditions of four exemptions outlined in the 2018
   Requirements (the Common Rule). The draft guidance discusses the concept of
   limited IRB review, which appears in these exemptions, and provides
   information about how limited review may be conducted. When finalized, this
   will provide the Office for Human Research Protections’ (OHRP) first formal
   guidance on this topic. This draft guidance was developed after taking into
   consideration input received from HHS and other Common Rule departments and
   agencies.
 * On June 15, 2023, the National Institutes of Health (NIH) issued a notice
   entitled, Implementation of the NIH Small Business Innovation Research
   Program and Small Business Technology Transfer Program Foreign Disclosure
   Pre-award and Post-Award Requirements. This notice announces publication and
   serves as a notice for the extramural community on recent policy changes made
   for the Small Business Innovation Research Program (SBIR) and the Small
   Business Technology Transfer Program (STTR). This notice implements
   additional disclosure requirements and post-award reporting requirements for
   small business concerns (SBCs) for covered relationships. In addition, this
   serves as notification of NIH’s due diligence program to assess security
   risks and denial of award when foreign relationships or commitments with
   countries of concern pose a significant risk as provided in the SBIR and STTR
   Extension Act of 2022. This policy also updates the Grants Policy section
   which will be incorporated in the fiscal year (FY) 2024 publication. In
   addition, the NIH Application Guide will be updated to reflect instructions
   for submission of required documentation.

Event Notices

 * June 27, 2023: HHS announced the annual President's Council on Sports,
   Fitness & Nutrition (PCSFN) meeting. The PCSFN will discuss plans for future
   projects and programs that may address but are not limited to: (1)
   implementing the National Strategy on Hunger, Nutrition, and Health,
   including supporting the White House Challenge to End Hunger and Build
   Healthy Communities; (2) raising awareness about the importance of mental
   health as it pertains to physical fitness and nutrition; (3) promoting the
   implementation of the National Youth Sports Strategy; (4) revitalizing the
   Presidential Youth Fitness Program; and (5) the launch of the Physical
   Activity Guidelines Midcourse Report: Implementation Strategies for Older
   Adults.
 * June 28, 2023: The Centers for Disease Control and Prevention (CDC) announced
   a town hall meeting regarding the history and future of CDC-funded public
   health preparedness and response centers. The purpose of this town hall
   meeting is to provide an overview and discussion of CDC-funded public health
   preparedness and response centers including the Centers for Public Health
   Preparedness and Response (CPHPs), Preparedness and Response Learning Centers
   (PERLCs), and Preparedness and Response Research Centers (PERRCs). The agenda
   will include presentations and discussions on three topic areas: (1)
   strengths and limitations of past CPHP, PERLC, PERRC and similar programs;
   (2) new program priorities as directed by sec. 2231 of the Consolidated
   Appropriations Act, 2023 (CAA, 2023); and (3) discussion of how best to meet
   state, territorial, local, and tribal public health preparedness and response
   needs in the design, implementation, and coordination of regional centers
   under CAA, 2023.
 * August 3, 2023: HHS announced a public meeting and related Request for
   Information (RFI) of the National Committee on Vital and Health Statistics
   (NCVHS) Workgroup on Timely and Strategic Action to Inform ICD-11 Policy. The
   purpose of the International Classification of Diseases (ICD-11) workgroup
   meeting is to gather information and identify gaps in currently available
   information and research essential for analysis and policy decisions on the
   U.S. approach to support adoption and implementation of ICD-11 for morbidity.
   A supplemental goal is to enable coordination of public and private entities
   that may affect ICD-11 integration into U.S. health information environments
   by obtaining broad stakeholder input on studies or assessments HHS should
   undertake to inform the transition and on what timeline. Together with
   comments received in response to the RFI, the input received at the
   roundtable will inform the Workgroup’s findings to be provided to the full
   Committee in contemplation of recommendations to the Secretary of HHS.

II. Hearings & Markups

U.S. House of Representatives

 * On June 13, 2023, the House Committee on Education & The Workforce held a
   hearing entitled, Examining the Policies and Priorities of the Department of
   Health and Human Services. Witnesses present included: The Honorable Xavier
   Becerra, Secretary, HHS.
 * On June 13, 2023, the House Committee on Oversight and Accountability
   Subcommittee on the Coronavirus Pandemic held a hearing entitled, Oversight
   of CDC Policies and Decisions During the COVID-19 Pandemic. Witnesses present
   included: Rochelle Walensky, M.D., M.P.H., Director, CDC.
 * On June 13, 2023, the House Committee on Energy and Commerce Subcommittee on
   Health held a legislative hearing entitled, Legislative Solutions to Bolster
   Preparedness and Response for All Hazards and Public Health Security Threats.
   Legislation considered during this hearing included: H.R. __, To reauthorize
   certain programs under the Public Health Service Act with respect to public
   health security and all-hazards preparedness and response, and for other
   purposes; H.R. __, the Public Health Guidance Transparency and Accountability
   Act; H.R. __, the PHEMCE Advisory Committee Act; H.R. __, the PHE
   Congressional Review Act of 2023; H.R. __, the Improving Contract
   Transparency for the SNS Act; H.R. __, the Improving Contract Transparency at
   BARDA Act; H.R. __, the Biosecurity Infrastructure for Operational (BIO)
   Early Warning Act; H.R. 3813, the CDC Leadership Accountability Act; H.R.
   3631, the State Strategic Stockpile Act of 2023; H.R. 3577, the Medical and
   Health Stockpile Accountability Act of 2023; H.R. 3837, the Improving Public
   Health Preparedness Act; H.R. 3832, the Disease X Act of 2023; H.R. 3613, the
   Doctors at the Ready Act; H.R. 2416, To amend the Public Health Service Act
   to reauthorize a military and civilian partnership for trauma readiness grant
   program; H.R. 3840, the Ensuring Sufficient Supply of Testing Act; H.R. 3795,
   To amend the Public Health Service Act to require the development of a
   diagnostic testing preparedness plan to be used during public health
   emergencies, and for other purposes; H.R. 3703, the Helping Evaluate
   Appropriate Logistical Infrastructure for National Government (HEALING)
   Response Act of 2023; H.R. 3742, To direct the Comptroller General of the
   United States to evaluate the Federal Government’s collection and sharing of
   public health data to respond to public health emergencies; H.R. 3820, To
   amend the Public Health Service Act to strike the requirement that the
   Director of the Centers for Disease Control and Prevention be appointed by
   and with the advice and consent of the Senate; H.R. 3794, the Fast-Track
   Logistics for Acquiring Supplies in a Hurry (FLASH) Act of 2023; and H.R.
   3791, the Improving Data Accessibility Through Advancements (DATA) in Public
   Health Act.
 * On June 14, 2023, the House Committee on Energy and Commerce Subcommittee on
   Health held a legislative hearing entitled, Examining Proposals that Provide
   Access to Care for Patients and Support Research for Rare Diseases.
   Legislation considered during this hearing included: H.R. 3226, the PREEMIE
   Reauthorization Act of 2023; H.R. 3838, the Preventing Maternal Deaths
   Reauthorization Act of 2023; H.R. 3843, the Action for Dental Health Act of
   2023; H.R. 3884, the Sickle Cell Disease and Other Heritable Blood Disorders
   Research, Surveillance, Prevention, and Treatment Act of 2023; H.R. 3821, the
   Firefighter Cancer Registry Reauthorization Act of 2023; H.R. 2365, the
   National Plan to End Parkinson’s Act; H.R. 3391, the Gabriella Miller Kids
   First Research Act 2.0; H.R. 3887, the Children’s Hospital GME Support
   Reauthorization Act of 2023; and H.R. 3836, the Medicaid Primary Care
   Improvement Act.

U.S. Senate

 * On June 15, 2023, the Senate Committee on Aging held a hearing entitled,
   Before Disaster Strikes: Planning for Older Americans and People with
   Disabilities in All Phases of Emergencies. Witnesses present included: DeeDee
   Bennett Gayle, Ph.D., M.S., Professor of Emergency Preparedness, Homeland
   Security, and Cybersecurity, SUNY; Annie Lloyd, Disability Policy Advocate;
   Jonathan Bydlak, Director of the Governance Program, R Street Institute; and
   Mahshid Abir, M.D., M.Sc., Emergency Physician and Health Services
   Researcher, RAND Corporation.
 * On June 15, 2023, the Senate Committee on Health, Education, Labor, and
   Pensions (HELP) held an executive session entitled, 133, S. 134, S. 265, S.
   1844, S. 1852, and S. 1855. Legislation considered during this executive
   session included: S. 133, NAPA Reauthorization Act; S. 134, Alzheimer’s
   Accountability and Investment Act; S. 265, SIREN Reauthorization Act; S.
   1844, Animal Drug and Animal Generic Drug User Fee Amendments of 2023; S.
   1852, Sickle Cell Disease and Other Heritable Blood Disorders Research,
   Surveillance, Prevention, and Treatment Act of 2023; and S. 1855, Special
   Diabetes Program Reauthorization Act of 2023.

III. Reports, Studies & Analyses

 * On June 12, 2023, the Kaiser Family Foundation (KFF) published an issue brief
   entitled, Employment Among Immigrants and Implications for Health and Health
   Care. In this issue brief, authors examine the socioeconomic characteristics
   and employment patterns among immigrant workers compared to U.S.-born workers
   and the implications of these patterns on the health and well-being of
   immigrants and the overall economy. The authors found that in 2021, nearly
   one in five adult workers between 19 and 64 years of age were immigrants and
   that among this population, noncitizen workers were more likely than citizen
   workers to work in construction, agricultural, and service jobs regardless of
   education level. Additionally, compared to citizen workers, noncitizen
   workers were more likely to be Hispanic or Asian, younger, and have lower
   levels of educational attainment. Even among those with college degrees,
   noncitizen workers were more likely than citizen workers to be low-income and
   uninsured. Further, while some noncitizen workers are in lower-wage jobs due
   to limited experience or lack of work authorization, others may be
   overqualified for their positions, which negatively affects immigrant
   families and the overall economy. Therefore, the authors conclude that
   increasing job opportunities that are more reflective of skill levels can
   improve the health and wellbeing of immigrants and their families as well as
   support the overall U.S. economy.
 * On June 13, 2023, the RAND Corporation published a study entitled, Expansion
   of Telehealth Availability for Mental Health Care After State-Level Policy
   Changes From 2019 to 2022. The authors note that although the COVID-19
   pandemic was the catalyst for the expansion of telehealth, state legislation
   may have also helped make the transition to telehealth more feasible. As
   such, they investigated the association between four state policies and
   telehealth availability at nearly 13,000 outpatient mental health treatment
   facilities in the U.S. Specifically, the four policies assessed included: (1)
   payment parity for telehealth services among private insurers; (2)
   authorization of audio-only telehealth services in Medicaid and the
   Children’s Health Insurance Program (CHIP); (3) participation in the
   Interstate Medical Licensure Compact (IMLC), which allowed for psychiatrists
   to provide telehealth across state lines; and (4) participation in the
   Psychology Interjurisdictional Compact (PSYPACT), which allowed for
   psychologists to provide telehealth across state lines. Authors found that in
   September 2022, over 88 percent of the facilities surveyed provided
   telehealth, compared to just 40 percent of facilities in April 2019. Although
   all four policies were associated with expansion of telehealth, authors found
   that telehealth services were less likely to be offered in counties with
   greater populations of Black residents and in facilities that accepted
   Medicaid and CHIP. The study concluded that more targeted action and policies
   could improve and expand telehealth to all populations.
 * On June 14, 2023, the CMS Office of the Actuary published its 2022-2031
   National Health Expenditure Projections. A related article summarizing its
   findings was entitled, National Health Expenditure Projections, 2022–31:
   Growth To Stabilize Once The COVID-19 Public Health Emergency Ends. Authors
   projected that national health expenditures will grow by 5.4 percent each
   year from 2022 to 2031, accounting for 19.6 percent of the gross domestic
   product (GDP) by 2031, compared to 18.3 percent in 2021. Additionally,
   authors predict that about 92.3 percent of the population will be insured in
   2022 and 2023, a historic high, but will decrease to about 90.5 percent of
   the population by 2031 as flexibilities and policies that expanded health
   insurance coverage during the COVID-19 pandemic expire. Medicare is expected
   to be the fastest growing payer over the course of 2022 to 2031, averaging
   about 7.5 percent per year. Further, hospital spending is expected to grow
   more rapidly (averaging 5.8 percent for 2022–31) than spending both for
   physician and clinical services (5.3 percent) and for prescription drugs (4.6
   percent). The authors also predict that legislation and policies, such as the
   Inflation Reduction Act (IRA) will also drive changes in spending and prices.
   For example, they predict that the prescription drug provisions in the IRA
   will lower overall growth in out-of-pocket payments and the end of the
   COVID-19 public health emergency (PHE) will reduce Medicaid enrollment and
   increase private insurance and Marketplace enrollment. In conclusion, federal
   actuaries predict that medical spending will continue to grow and become a
   larger part of household spending over the next 10 years.
 * On June 15, 2023, the Government Accountability Office (GAO) published a
   report entitled, Federal Research: NIH Could Take Additional Actions to
   Manage Risks Involving Foreign Subrecipients. Responding to a congressional
   request, GAO assessed the amount of federal funding provided to three select
   Chinese entities – Wuhan University; the Wuhan Institute of Virology (WIV);
   and the Academy of Military Medical Sciences – in calendar years (CY) 2014
   through 2021 and steps the agencies and award recipients have taken to assess
   potential risks. GAO found that most of the funding awarded to the three
   Chinese entities came from NIH and that NIH awarded over $2 million in total
   to them. GAO noted that NIH did not always ensure that foreign institutions
   complied with award terms and conditions, including biosafety requirements.
   In January 2023, HHS’ Office of Inspector General (OIG) recommended NIH take
   steps to enhance monitoring, documentation, and reporting requirements for
   award recipients with foreign subrecipients, to which NIH noted it will need
   additional authorities and time to fulfill. As such, GAO recommends that NIH
   take steps to enhance its internal oversight in the more immediate timeframe
   as it takes pursues longer-term actions for award recipients.
 * On June 15, 2023, the Congressional Budget Office (CBO) published a cost
   estimate entitled, R. 2813, Self-Insurance Protection Act. H.R. 2813 would
   impose an intergovernmental mandate that preempts any state laws that prevent
   certain group health plans from using stop-loss policies to insure against
   excess or unexpected claims losses. CBO and the Joint Committee on Taxation
   (JCT) estimate that enacting H.R. 2813 would have insignificant effects on
   direct spending, revenues, and deficits over the 2023-2033 period. CBO and
   JCT’s analysis of state laws indicates that few states prohibit the sale of
   stop-loss coverage; thus, the bill’s preemption of state laws would affect
   only a small number of people. The bill would also not impose any
   private-sector mandates.
 * On June 15, 2023, the Medicare Payment Advisory Commission (MedPAC) released
   its June Report to Congress. The report included chapters on topics such as
   standardized benefits in Medicare Advantage (MA) plans, disparities in
   outcomes for Medicare beneficiaries with different social risks, telehealth
   in Medicare, and aligning fee-for-services (FFS) payment rates across
   ambulatory settings. Among its recommendations, MedPAC expressed support for
   more closely aligning Medicare payment rates between hospital outpatient
   departments, ambulatory surgical centers, and freestanding physician offices.
   MedPAC also presented data on the utilization of telehealth services during
   the COVID-19 PHE. MedPAC’s findings suggest that during the pandemic,
   increased telehealth utilization was associated with minimal change in
   measured quality, slightly improved access to care for some beneficiaries,
   and slightly increased costs to the Medicare program.
 * On June 15, 2023, the Medicaid and CHIP Payment and Access Commission
   (MACPAC) issued its June Report to Congress. The four chapters included in
   the report were: (1) Countercyclical Medicaid Disproportionate Share Hospital
   Allotments; (2) Integrating Care for Dually Eligible Beneficiaries: Different
   Delivery Mechanisms Provide Varying Levels of Integration; (3) Access to
   Medicaid Coverage and Care for Adults Leaving Incarceration; and (4) Access
   to Home-and Community-Based Services. Specifically, Chapter 2 focused on the
   delivery system mechanisms available for implementing integrated care for
   dually-eligible beneficiaries. Additionally, the report highlighted ways to
   expand and increase access to home-and-community-based services (HCBS).

IV. Other Health Policy News

 * On June 12, 2023, the Kidney Innovation Accelerator (KidneyX), a public
   private partnership between HHS and the American Society of Nephrology (ASN)
   announced the eight winners of the Artificial Kidney Prize Phase 2.
   Competitors worked to develop a prototype bioartificial kidneys or a new tool
   or component that can help enable the development of bioartificial kidneys.
   Developing bioartificial kidneys has historically been difficult to do
   because of the overall complexity of the organ, which is made up of many
   different cell types and performs several important functions. Through this
   prize competition, KidneyX sought innovative ways to address kidney disease,
   for which the best currently available treatment is a kidney transplant;
   however, the supply of kidneys only addresses a small fraction of the need.
   With over 37 million Americans and 850 million people worldwide living with
   kidney disease, innovation to address this illness is urgent. The eight
   winners included doctors, scientists, and engineers of the regenerative
   medicine, cellular engineering, tissue engineering, systems biology and
   synthetic biology specialties. More information on this announcement can be
   found here.
 * On June 12, 2023, the Biden-Harris Administration announced new tools
   designed to lower prescription drug costs for low-income people with Medicare
   through the Extra Help program, which provides eligible seniors and disabled
   people with help paying for their Medicare Part D premiums and cost-sharing.
   Specifically, the IRA expanded eligibility for subsidies provided under the
   Extra Help program, to individuals with limited resources and incomes up to
   150 percent of the federal poverty level (FPL) beginning January 1, 2024.
   HHS, the Administration for Community Living (ACL) and the Centers for
   Medicare & Medicaid Services (CMS), are working to expand outreach to
   eligible seniors and people with disabilities to improve enrollment in the
   Extra Help program. For example, CMS is making available an outreach tool kit
   and releasing national data on people with Medicare Part D prescription drug
   coverage who currently benefit from Extra Help. The expansion of the Extra
   Help program provides an important opportunity to those who could benefit
   from the program’s lower cost premiums, deductibles, and copayments—now and
   when the program expands in 2024. More information on this announcement can
   be found here.
 * On June 12, 2023, HHS announced new flexibilities aimed at keeping
   beneficiaries covered as states resume Medicaid and CHIP renewals following
   the end of the COVID-19 PHE. During the PHE, individuals were not required to
   resubmit eligibility documentation for Medicaid and CHIP. However, following
   the end of the PHE, states have begun a “redetermination” process to reassess
   eligibility. HHS provided for these expanded flexibilities given the agency’s
   concern with the number of people who are at risk or are losing coverage
   during the redetermination process. Some of the new flexibilities announced
   include: (1) allowing managed care plans to either assist with Medicaid
   renewal applications or complete renewal applications on behalf of
   beneficiaries, (2) allowing states to delay administrative termination of
   beneficiaries who do not complete renewals on time, and (3) allowing
   pharmacies and community-based organizations (CBOs) to reinstate coverage for
   certain individuals disenrolled from Medicaid and CHIP for procedural
   reasons. More information on this announcement can be found here.
 * On June 13, 2023, HHS and CMS announced New York’s extension of comprehensive
   coverage through Medicaid and CHIP for 12 months postpartum. New York is the
   35th state, along with the District of Columbia (D.C.), to offer this
   postpartum coverage extension from the current mandatory 60-day period to 12
   months. As a result, an additional 26,000 people in New York and an estimated
   509,000 people in total will remain eligible for Medicaid and CHIP for a year
   after pregnancy. These efforts to extend Medicaid and CHIP postpartum
   coverage is part of ongoing efforts through HHS and the Biden Administration
   to address disparities in maternal health outcomes. More information on this
   announcement can be found here.
 * On June 14, 2023, HHS, through the Health Resources and Services
   Administration (HRSA), announced nearly $9 million in grant funding to 20
   grantees to help them strengthen and expand the mental health and substance
   use workforce in underserved and rural communities. The grants can be used to
   train health care providers to care for individuals in need of mental health
   services through the Integrated Substance Use Disorder Training Program
   (ISTP). This program will help community-based programs upskill their
   workforce and increase the number of mental health and substance use disorder
   (SUD) providers available (including nurse practitioners and physician
   assistants) trained to provide mental health and SUD treatment, including
   opioid use disorder (OUD) services. More information on this announcement can
   be found here.
 * On June 15, 2023, ACL announced that it is seeking input on its proposed
   updates to the regulations for its Older Americans Act (OAA) programs. ACL
   notes that the proposed rule aims to align regulations to current statute,
   which has evolved since the current OAA regulations were first established,
   and to reflect the needs of older adults today. The population of older
   adults has nearly doubled, older adults are living longer than ever before,
   and health care providers are incorporating an increased understanding about
   social determinants of health (SDOH) into their care practices. As such, the
   proposed rule will clarify requirements across many programs, including new
   ones authorized by the OAA since the last update of the rule; will address
   increased requirements and flexibilities for providers serving older adults
   during emergencies; will take steps to better support older adults to stay in
   their homes; and more. More information on this announcement can be found
   here.
 * On June 16, 2023, the Department of Education (ED) and HHS took additional
   steps to advance the investments and efforts set forth by the Bipartisan
   Safer Communities Act (BSCA). BSCA takes action to prevent and respond to gun
   violence in communities and to make sure children in schools have access to
   mental health services. ED and HHS are working together on BSCA
   implementation in response to the increasing amount of challenges youth are
   facing in their schools and in their communities, such as increased
   loneliness and gun violence. For example, both Departments have provided
   funding and established programs that would make available resources to help
   communities expand school-based mental health services, make schools more
   welcoming and safe environments, establish afterschool programs, and train
   school personnel and law enforcement to care for children and communities
   following incidents of gun violence. More information on this announcement
   can be found here.

View our Health Care Legislative & Public Policy team.

Did you miss a week? Browse our Health Care Week in Review archive.

Robert D. Stone
Partner
Phone: +1 404 881 7270
Email: rob.stone@alston.com
Timothy P. Trysla
Partner
Phone: +1 202 239 3420
Email: tim.trysla@alston.com
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