APHL’s Policy Program promotes the work of governmental public health laboratories by advocating for a sustainable laboratory network and voicing the impact of federal regulatory rules on public health laboratories.
Informatics Policy Initiatives
APHL is committed to improving population health through informatics, health IT and information exchange and works to assure that informatics standards and architectures support the critical work of public health laboratories.
APHL Comment FSIS Accredited Laboratory Program (February 2021)
APHL Comment NARMS Strategic Plan (November 2020)
APHL Comment FSIS Salmonella Roadmap (October 2020)
APHL Comment Laboratory Accreditation for Analysis of Foods (March 2020)
APHL Comment New Era of Smarter Food Safety (November 2019)
APHL Comment to AMS (January 2020)
APHL Comment to FDA (July 2019)
APHL Comment To HHS Environmental Justice Strategy Draft (June 2022)
APHL Comment to EPA Strategic Plan 2022-2026 (November 2021)
APHL Response to NIH Climate and Health RFI (September 2021)
APHL Comment CDC LEPAC (October 2020)
APHL Comment EPA Transparency Rule (May 2020)
APHL Comment to EPA On Lead and Copper Rule Revisions (March 2020)
APHL Comment to EPA on Water Reuse (December 2019)
APHL Comment to CMS on Lead Testing (April 2019)
APHL Comment to USDA APHIS Proposed Frameowwork for SARS-CoV-2 and Other Emerging Zoonotic Diseases (October 2021)
FDA Re-classification of HIV/HCV Diagnostics
APHL supports the reclassification of these devices from Class III to Class II to improve access to state of the art HIV and HCV tests, patient diagnosis, laboratory efficiency, patient management, and public health surveillance.
2018 Common Rule
Federal policy that protects human subjects in federally funded research. Revised Common Rule in effect as of 7/19/18.
Laboratory Developed Tests
Response to congressional and FDA activities regarding revised oversight of in vitro diagnostic tests including LDTs.
CMS Reimbursement Rates
Data Integrity of Private Payer Rates of CLFS
APHL joined organizations in the laboratory community to raise concerns of the integrity of the data CMS collected when determining accurate weighted median of private payer rates for tests on the Clinical Laboratory Fee Schedule (CLFS). The letters urge Seema Verma, Administrator of CMS, to involve all stakeholders when calculating and establishing pricing.
CLFS Funding Cuts
APHL led a group
of governmental public health organizations in a letter to Congress to oppose the cuts to the CLFS that were set to take place in January 2018. ASTHO, NACCHO, CSTE, AMCHP, NASTAD and NCSD joined APHL in calling on Congress to immediately suspend the implementation of the new CLFS rates which cut testing of public health importance up to 35-40%.
Repeal of Prevention and Public Health Fund
APHL sent letters to Senate leadership stating to continue provide funding for critical public health programs that are currently funded from the Prevention and Public Health Fund (PPHF), a component of the Affordable Care Act (ACA).
APHL joined on two letters to congressional leadership urging continued federal funding for Zika response activities.
Multiplex Nucleic Acid Amplification Test