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BISNonrulemakingBIS-2025-0258

Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, Medical Equipment, and Their Parts and Components

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American Health Care Association (AHCA/NCAL) filings
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American Health Care Association (AHCA/NCAL) filed 1 comment on this docket between Oct 22, 2025 and Oct 22, 2025. 202 other organizations filed here. The comment window closed 284d ago.

What American Health Care Association (AHCA/NCAL) filed (1)

Oct 22, 2025· American Health Care Association | National Center for Assisted Living. 10/16/2025· BIS-2025-0258-0147

Dear Deputy Assistant Secretary Khersonsky, On behalf of the American Health Care Association and the National Center for Assisted Living (AHCA/NCAL), thank you for the opportunity to submit comments to the U.S. Department of Commerce's Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment, Including Devices. AHCA/NCAL's members are long term and post-acute care providers, who are significant users of the medical supplies within the scope of this investigation. As such, we encourage the administration to work towards solutions that preserve our membership's ability to serve our nation's most vulnerable populations and avoid undue financial strain on a health care sector that uniquely relies on Medicaid and Medicare. AHCA/NCAL is the largest association in the United States representing long term and post-acute care providers with more than 15,000 member facilities. Our diverse membership includes non-profit and proprietary nursing homes, assisted living communities, and intermediate care facilities (ICFs) for individuals with intellectual and developmental disabilities. By delivering solutions for quality care, AHCA/NCAL aims to improve the lives of the millions of frail, elderly and individuals with disabilities who receive long term or post-acute care in our member facilities each day. Long term and post-acute care is still slowly recovering from the COVID-19 pandemic and recent years of record inflation. From 2020 to 2024, 774 nursing homes closed, displacing more than 28,000 residents. The sector is also still recovering from historic job losses and is continuing to dedicate significant resources toward the recruitment and retention of caregivers. Providers need to continue to invest in their care services, labor, and modernization efforts—all while on fixed government rates—in order to enhance the quality of care being delivered and prepare for the nation's growing elderly population. Increasing tariffs on medical supplies would ultimately divert precious taxpayer resources away from patient care and these improvement efforts. For those facilities operating on the brink, it could mean having to shutter their doors for good. Recommendation #1: Provide Annex II and Annex III Eligibility for High-Use, Low-Cost Medical Supplies with Allied Nations An alternative approach that would ensure supply chain security and resiliency is to include these products in allied nation negotiations. Inclusion in Annex III would allow the administration to work with countries such as Mexico, the Dominican Republic, Cambodia, Indonesia, Malaysia, Pakistan, Thailand, Vietnam and Kenya to continue access to affordable medical supplies. As the administration has done for other pending 232 investigations, we also respectfully request that these products be added to Annex II to ensure consistent treatment across the priority national security industries as this investigation continues. Recommendation #2: Preserve Eligibility Under Chapter 98 of the Harmonized Tariff Schedule of the U.S. The administration has extended eligibility for certain products qualifying under Chapter 98 of the Harmonized Tariff Schedule of the U.S. as part of previous tariff actions, which provides duty-free treatment under certain circumstances, including provisions that address tariff treatment of U.S. components assembled abroad without alteration. To ensure consistency in tariff implementation, we recommend extending that same framework to the Section 232 investigation. We are grateful that the Trump Administration has already taken important steps to support our nation's seniors, their families, and their caregivers. From shielding nursing homes and ICFs from Medicaid reductions in the One Big Beautiful Bill Act to rescinding the Biden Administration's unrealistic staffing mandate, we appreciate that the Administration wants to ensure that federal policies protect access…

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Abstract

On September 2, 2025, the Secretary of Commerce initiated an investigation to determine the effects on the national security of imports of personal protective equipment (PPE), medical consumables, and medical equipment including devices. This investigation has been initiated under section 232 of the Trade Expansion Act of 1962, as amended (Section 232). Interested parties are invited to submit written comments, data, analyses, or other information pertinent to the investigation to the Department of Commerce's (Department) Bureau of Industry and Security (BIS), Office of Strategic Industries and Economic Security. This notice identifies issues on which the Department is especially interested in obtaining the public's views.

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Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Personal Protective Equipment, Medical Consumables, Medical Equipment, and Their Parts and Components (BIS) — American Health Care Association (AHCA/NCAL) | OpenPolis