Wednesday, December 7, 2022

New CMS Proposed Rule Released on PatientAccess and a Feature Request for the @FedRegister Web Site

 CMS Announced the updates to the Patient Access Rule yesterday.  So another tweet tweet through and summary are coming by EOW (my time zone).  You can find the preview here.  My comments on the prior rule are here, and you might read that first before starting on this one.

I'm not going to get through this one right away because I have other high priority tasks in front of that (releasing is a very important feature).

I've been a Federal Register user for quite some time.  I really appreciate all the work that has gone into it, especially for reviewing regulation.  My biggest use of it is for providing feedback on regulations, and that leads me to a feature request or three that I'd love to see.

  1. Provide users with the capability to make notes on individual paragraphs and sentences in a publication requesting feedback (e.g., a rule or proposed rule).
  2. Enable users to coordinate with other users so that multiple users can make notes in the same note repository.
  3. Enable users to access and download that feedback in a machine readable, preferably standardized format.
  4. Enable users to upload/merge feedback from other exports into a note repository.
  5. Enable users to share a link to that feedback with others for read or write access.
  6. Enable users to automatically submit a repository with additional attachments as feedback on a proposed rule, RFI or other publication.
  7. Annotations should take the format: Link to original text (a span of text in the rule), proposed wording, comments, and author.  See the last paragraph below for why this is the format.
What this would do is enable users to comment on regulations, provide a standardized format that would enable federal agencies to automate much of the work of coordinating comments from different users, and enable feedback to be tied directly back to required sections.  This could vastly improve response times for feedback.

I try to provide feedback on regulations the same way as I do for standards: Here's the original text, here's how it should read, and here's why.  When writing the "how it should read", I try to use the same voice as the original proposed rule so that the text can just be copy-pasted into the final rule. It makes everyone's day easier, and that's how I've gotten verbatim text I and my colleagues have written to appear in at least three different rules (yes, you too can write text that appears in a final rule).



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