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    August 20, 2021 

    James Frederick
    Acting Assistant Secretary of Labor
    Occupational Safety and Health Administration
    U.S. Department of Labor
    200 Constitution Avenue NW
    Washington, D.C. 20210

    Electronically submitted via

    Re: Occupational Exposure to COVID-19; Emergency Temporary Standard

    Dear Acting Assistant Secretary Frederick,

    On behalf of our member medical group practices, the Medical Group Management Association (MGMA) writes to express our shared commitment to protect healthcare workers from contracting COVID-19. While we appreciate that the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) is attempting to protect healthcare workers through the COVID-19 healthcare emergency temporary standard (ETS), we believe the ETS was issued much too late and as a result, will disrupt the ongoing efforts of medical groups to balance the needs of patients against the imperative to protect employees.

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