While the regulatory process had been completed and the final regulations reported in the Federal Registry, HHS had not yet developed guidelines for implementation. [A contact at HHS confirms] the Department believes the regs. fall under President Obama’s executive order “freezing all last minute Bush administration regulations for review prior to final implementation”.
We waited to report this until she had confirmed with her DHHS source, and although we are still waiting for an official DHHS statement, we felt we had to report at this point.
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