Administrative Comments | First Focus on Children https://firstfocus.org/resources/administrative-comments/ Making Children and Families the Priority Thu, 04 Apr 2024 18:48:08 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.5 https://firstfocus.org/wp-content/uploads/2023/12/cropped-image-4-32x32.png Administrative Comments | First Focus on Children https://firstfocus.org/resources/administrative-comments/ 32 32 Comments on Hawaii Section 1115 Demonstration Waiver Request https://firstfocus.org/resource/comments-on-hawaii-section-1115-demonstration-waiver-request/ Wed, 14 Feb 2024 03:08:57 +0000 https://firstfocus.org/?post_type=resource&p=29198 First Focus on Children submitted the following comment to Xavier Becerra, Secretary of the Department of Health and Human Services, and Chiquita Brooks-LaSure, Administrator of the Centers for Medicare & Medicaid Services encouraging them to approve the waiver and allow Hawaii to offer early childhood continuous eligibility through ages 0-5. Excerpt from the Comment: Currently, …

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First Focus on Children submitted the following comment to Xavier Becerra, Secretary of the Department of Health and Human Services, and Chiquita Brooks-LaSure, Administrator of the Centers for Medicare & Medicaid Services encouraging them to approve the waiver and allow Hawaii to offer early childhood continuous eligibility through ages 0-5.

Excerpt from the Comment:

Currently, Hawai’i offers continuous eligibility for 12 months for all children ages 0-18 enrolled in Medicaid, as required by federal law as of January 1, 2024. While this is a positive step towards keeping children insured, state data shows that “churn,” which occurs when a child is unduly disenrolled and then subsequently re-enrolled within a year, impacts one in four disenrolled children in Hawai’i. Gaps in both coverage and access to care can be detrimental to a child’s development. Even a short gap in coverage can harm a child by reducing their access to necessary care. If a coverage gap is prolonged, families may face expensive medical bills or may push off their child’s care due to high out-of-pocket costs. Churn also impacts low-income families and families of color more heavily, as their incomes are more likely to fluctuate in and out of eligibility levels during the year.

Read the full comment.

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Comments on Minnesota Section 1115 Demonstration Waiver Request https://firstfocus.org/resource/comments-on-minnesota-section-1115-demonstration-waiver-request/ Wed, 14 Feb 2024 03:08:12 +0000 https://firstfocus.org/?post_type=resource&p=29195 First Focus on Children submitted the following comment to Xavier Becerra, Secretary of the Department of Health and Human Services, and Chiquita Brooks-LaSure, Administrator of the Centers for Medicare & Medicaid Services encouraging them to approve the waiver and allow Minnesota to offer early childhood continuous eligibility through ages 0-5. Excerpt from the Comment: Currently, …

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First Focus on Children submitted the following comment to Xavier Becerra, Secretary of the Department of Health and Human Services, and Chiquita Brooks-LaSure, Administrator of the Centers for Medicare & Medicaid Services encouraging them to approve the waiver and allow Minnesota to offer early childhood continuous eligibility through ages 0-5.

Excerpt from the Comment:

Currently, Minnesota offers continuous eligibility for 12 months for all children ages 0-18, as required by federal law as of January 1, 2024. While this is a positive step towards keeping children insured, state data shows that “churn,” which occurs when a child is unduly disenrolled and then subsequently re-enrolled within a year, disproportionately impacts children of color in Minnesota. Gaps in both coverage and access to care can be detrimental to a child’s development. Even a short gap in coverage can harm a child by reducing their access to necessary care. If a coverage gap is prolonged, families may face expensive medical bills or may push off their child’s care due to high out-of-pocket costs. Churn also impacts low-income families and families of color more heavily, as their incomes are more likely to fluctuate in and out of eligibility levels during the year.

Read the full comment.

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Comments on WIC Access to Baby Formula Act of 2022 https://firstfocus.org/resource/comments-on-wic-access-to-baby-formula-act-of-2022/ Tue, 13 Feb 2024 03:07:20 +0000 https://firstfocus.org/?post_type=resource&p=29193 First Focus on Children submitted the following comment to Allison Post, Chief, WIC Administration, Benefits, and Certification Branch Policy Division, Food and Nutrition Service at the U.S. Department of Agriculture on the Access to Baby Formula Act of 2022 and Related Provisions — a proposed rule that will help maintain access to infant formula. Excerpt …

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First Focus on Children submitted the following comment to Allison Post, Chief, WIC Administration, Benefits, and Certification Branch Policy Division, Food and Nutrition Service at the U.S. Department of Agriculture on the Access to Baby Formula Act of 2022 and Related Provisions — a proposed rule that will help maintain access to infant formula.

Excerpt from the Comment:

USDA’s rule codifies the strides made by the Access to Baby Formula Act of 2022 (ABFA; PL 117-129), which was passed with bipartisan support in response to the baby formula shortage in 2022. This rule will ensure that mothers and infants have access to formula during emergencies like natural disasters, public health emergencies, or supply chain disruptions. Ensuring access to formula ensures that babies across America, especially our low-income communities and communities of color, have consistent and equitable access to the nutrition they need to thrive. Enacting this rule ensures that WIC helps to prevent shortages in the future, which is a necessary and commendable step.

Read the full comment.

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Letter: Keep children front & center in paid leave policies https://firstfocus.org/resource/letter-keep-children-front-center-in-paid-leave-policies/ Fri, 02 Feb 2024 03:05:34 +0000 https://firstfocus.org/?post_type=resource&p=29189 First Focus on Children sent the following letter to Senators Gillibrand and Cassidy as well as Representatives Houlahan and Bice to thank them for their commitment to addressing the challenges that children and families face in accessing paid leave and identifying policy solutions for this problem. They were also urged to keep children front and …

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First Focus on Children sent the following letter to Senators Gillibrand and Cassidy as well as Representatives Houlahan and Bice to thank them for their commitment to addressing the challenges that children and families face in accessing paid leave and identifying policy solutions for this problem. They were also urged to keep children front and center as they consider the impact paid leave policies will have on the nation.

Excerpt from the letter:

The United States needs a federal paid leave policy to ensure equitable access to paid leave and all the benefits it creates for families. The current patchwork of local, state, and private actions has proven to be inadequate. The U.S. is the only wealthy country in the world that does not offer paid parental leave at the national level. Thirteen states and the District of Columbia have enacted paid family and medical leave laws, and eight others have voluntary systems. Though these states have acted and are seeing benefits for their residents, the need for a federal policy is clear: the Bureau of Labor Statistics shows that only about 1‑in‑4 private sector employees has access to paid family leave, and Hispanic and Black workers are much less likely to have access than their white counterparts. Of the lowest-income workers, only 6 percent have access to paid family leave. These inequities harm children and demand a federal paid leave policy that includes all workers, including independent contractors, part-time and full-time workers, and both public and private sector employees, regardless of industry or employer size.

Read the full letter.

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Comments on National Primary Drinking Water Regulations for Lead and Copper https://firstfocus.org/resource/comments-on-national-primary-drinking-water-regulations-for-lead-and-copper/ Sat, 20 Jan 2024 02:55:00 +0000 https://firstfocus.org/?post_type=resource&p=29174 First Focus on Children submitted the following comment to Dr. Jennifer L. McLainm, the Director of the Office of Ground Water and Drinking Water at the U.S. Environmental Protection Agency to applaud the EPA for taking steps to update America’s outdated infrastructure and provide clean, safe drinking water for all. Excerpt from the Comment: There …

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First Focus on Children submitted the following comment to Dr. Jennifer L. McLainm, the Director of the Office of Ground Water and Drinking Water at the U.S. Environmental Protection Agency to applaud the EPA for taking steps to update America’s outdated infrastructure and provide clean, safe drinking water for all.

Excerpt from the Comment:

There is no safe blood lead level (BLL) for children, meaning that any and all lead exposure could potentially lead to severe health consequences. Children drink more water per pound of body weight than adults, making them more susceptible to smaller levels of lead. Additionally, lower blood levels of lead cause greater impacts on children than in fully-developed adults. Infants are perhaps at the most risk of consuming lead in drinking water, as those who consume formula may receive up to 60% of their lead exposure via water (as compared to 20% for the average person).

Read the full comment.

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