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Commenting on the Birth Certificate Regulations. The Regulation Process and Beyond:. Philosophy of Regulation Development. To maintain a state-based birth registration and certification system with ownership of the data remaining with the states .
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Commenting on the Birth Certificate Regulations The Regulation Process and Beyond:
Philosophy of Regulation Development • To maintain a state-based birth registration and certification system with ownership of the data remaining with the states. • To make a more secure, timely, responsive birth registration and certification system and specifically to improve security of collection, handling & issuing of birth certificates.
Philosophy of Regulation Development • To make a more connected birth certificate system • Improve the flow of information within and between states and between the states and the Federal Government. • No death certificate regulations except as necessary to make birth certificates more secure
Status of Regulations • Initial DHHS review completed in 2006 • Modifications completed in early 2007 • Revised regulations sent to CDC and HHS reviews in May 2007 • Next step---OMB review • Later—Public review
Public Comments • Who should comment---Everyone !! (“Consensus” comments as well as the “maverick” comments) • 60 day public review period
Public Comments • Electronic access----- www.Regulations.gov • Through this website: • Enter your comments • Review the comments of anyone else • Enter new comments based on your review of other’s comments
Public Comments • What to be commented on: • Preamble • Regulation • Economic analysis • Comments received will be reviewed and summarized. • Summarization to be included in the revised NPRM
Other Methods for Commenting • Other ways to provide comments • Emails to NCHS • Written letters • Telephone calls • Personal conversations • All comments received will be entered into www.regulations.gov
Other Methods for Commenting • Reading Room to be created at NCHS • Reading Room Capabilities • Assess the internet • Submit comments • Review comments submitted • Make copies of comments
Other Methods for Commenting • These “other methods” are not the preferred approach!!
Most Helpful Comments • Identify the specific regulation • Explain the reason for any change • Provide the recommended change • Include supporting data, with proper documentation
Privacy of Comments • All comments are public • Exception is Proprietary or confidential business information, which must be: • Delivered by mail directly to NCHS. • Clearly marked as proprietary • Will not be placed in public file, but a note about its receipt will be • Subject to the Freedom of Information Act. Case-by-case decision.
After Comment Period………. • Summarize all comments received • Produce a report of the summarized comments • Revise the preamble, regulations and/or economic analysis based on comments • Submit revised draft for internal review
Internal Review Process • NCHS/CDC---about 30 days • DHHS---from 30 to 60 days • OMB----90 days
Implementation • Release approved regulations in the Federal Register • 30 days after this release, the regulations become effective • Clock begins!
In Closing • Not everyone will agree with everything stated---none of us will agree with everything. • Note your differences along with the reasons and supporting data. • Be “open” to change