Lexology March 12, 2025
On March 3, 2025, the United States Department of Health and Human Services (“HHS”) issued a policy statement rescinding the Richardson Waiver, a policy in place since 1971 that required notice-and-comment rulemaking for regulations on public property, loans, grants, benefits, or contracts. Under the new framework, HHS and its subagencies now have greater discretion to decide when to seek public input, and HHS has expanded its ability to bypass notice-and-comment altogether using the “good cause” exception of the Administrative Procedure Act (“APA”).
A copy of the policy statement can be found here.
Key Changes Under the New Policy
One of the most immediate effects of rescinding the Richardson Waiver is that HHS may now issue regulations, including those relating to...
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