As the implementation of federal health care reform continues full steam ahead, it is worth taking a quick pause to reflect upon how an “interim final rule” works, and to identify the major players in the implementation of such a large and sweeping piece of federal legislation.
The Department of Health and Human Services (HHS), lead by Secretary Kathleen Sebelius, has been tasked as the lead federal agency to issue rules as part of the massive implementation of the Patient Protection and Affordable Care Act of 2010 (PPACA). Together with the Department of Labor (DOL) and the Department of the Treasury, HHS has issued a series of interim final rules (IFRs). Even though the IFRs are subject to public comments throughout a specified comment period, they still have full force of law as presently written. Continue reading ‘The strange new world of interim final rules’
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