The Virginia Hospital & Healthcare Association has shared with numerous planning and legal experts these fast-track regulations proposing the use of the Consumer Price Index for All Urban Consumers (CPI-U) to update the annual capital expenditure threshold.  We appreciate this opportunity to submit these comments noting the consensus among these experts on the proposal.  Generally, we support the use of the CPI-U to calculate the capital expenditure threshold.  However, we suggest that the regulations should be clarified in two respects:

• While the draft regulation refers to “expense category,” the proper term seems to be “expenditure category.” 
• The draft regulation references the “expense category ‘Medical Care.’”  However, the CPI-U includes two categories similarly named – “Medical care commodities” and “Medical care services.” This reference should be clarified.