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PHI Joins Coalition Backing Senate Resolution to Restore Public Comment at HHS

May 5, 2025

PHI has joined more than 60 other leading health, labor, and advocacy organizations in supporting a new Senate resolution that calls on the Trump administration to reverse its decision to eliminate public comment periods regarding many significant policy and programmatic changes at the Department of Health and Human Services (HHS).

The resolution, introduced by Senators Ron Wyden (D-Oregon), Edward Markey (D-Massachusetts), and Angus King (I-Maine), addresses the administration’s March 2025 decision to halt the long-standing practice of seeking public input on changes to HHS programs and policies—a practice fundamental to democratic policy development for over five decades.

A Critical Loss of Worker Voice

PHI stands with a broad coalition endorsing this resolution, demonstrating a wide consensus that public input is essential for fair, effective policy.

“For decades, PHI has utilized the notice and comment process to inform U.S. healthcare policy, ensuring it reflects the realities of the critical, yet often-overlooked, direct care workforce. Eliminating this process would silence the voices of workers, family caregivers, older adults, people with disabilities, and advocates at a crucial moment for care in the United States. Effective policymaking requires input from the data, expertise, and on-the-ground experience that PHI and other advocates provide, and it must account for the potential impact of policy changes on the vast number of Americans who deliver and rely on care.” – Jodi M. Sturgeon, President and CEO, PHI

Why This Matters

The policy implications of this decision are profound and wide-reaching. Without formal channels for input, the perspectives of the direct care workforce—home care workers, residential care aides, and nursing assistants—will be excluded from policies that directly impact their compensation, working conditions, training requirements, and professional advancement, not to mention the perspectives of the millions of older adults, people with disabilities, and family caregivers that direct care workers support each day.

Direct care  workers, who are predominantly women and disproportionately  women of color and immigrants, have long been marginalized in policy discussions despite their critical contributions to our nation’s long-term care infrastructure. Restoring the full public comment process is not merely about administrative procedure, it’s about fundamental fairness and recognition to these workers’ contributions, expertise, and lived experiences.

This move also curbs the voices of workforce development experts, researchers, and educators who have dedicated careers to understanding the complex needs of the direct care sector. Their evidence-based insights on training standards, career pathways, and retention strategies effectively become inaccessible to policymakers overnight, undermining years of field research and proven best practices.

Similarly, employers and providers lose a critical avenue for sharing operational realities and implementation challenges. These stakeholders rely on the comment process to inform HHS about how policies translate in practice, seek critical clarification from policymakers about regulatory requirements and implementation timelines, and what adjustments might better serve both workers and care recipients. Without this feedback loop, HHS risks enforcing policies that are disconnected from frontline realities.

Taking Action

The resolution specifically calls on the Secretary of Health and Human Services to withdraw the notice published in the Federal Register that reduced public comment opportunities and restore the practices that were in place before February 27, 2025.

PHI urges our partners across the sector to:

  1. Review the full Senate resolution.
  2. Share the press release.
  3. Contact your senators to demand their support for this critical resolution.

The direct care workforce deserves policies that reflect their lived experiences and professional expertise. We must ensure their voices remain central to the decisions that affect their lives, their work, and the quality of care they deliver. As sweeping policy changes make their way through the federal government,  the stakes for direct care workers—and for all of us—have never been higher.

 

Contributing Authors
PHI

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