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Your Comments Needed on Proposed Rule
We urge you to submit comments to CMS on the proposed emergency preparedness rule before the 3/31/14 deadline.
Please review the proposed rule and submit comments online.
Proposed Rule:
http://www.regulations.gov/#!documentDetail;D=CMS-2013-0269-0002
Online Comment Submission:
http://www.regulations.gov/#!submitComment;D=CMS-2013-0269-0002
You may refer to the guidelines provided below to develop your submission.
Guidance for your comment
A constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.
Summary
- Read and understand the regulatory document you are commenting on
- Be concise but support your claims
- Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
- Address trade-offs and opposing views in your comment
- There is no minimum or maximum length for an effective comment
- The comment process is not a vote - one well supported comment is often more influential than a thousand form letters
Form Letters
Many in the public mistakenly believe that their submitted form letter constitutes a "vote" regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and scientific evidence, not a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.
Detailed Recommendations
- Clearly identify the issues within the regulatory action on which you are commenting. If you are commenting on a particular word, phrase or sentence, provide the page number, column, and paragraph citation from the federal register document.
- If a rule raises many issues, do not feel obligated to comment on every one - select those issues that concern you the most, affect you the most, and/or you understand the best.
- Although agencies receive and appreciate all comments, constructive comments (either positive or negative) are the most likely to have an influence.
- If you disagree with a proposed action, suggest an alternative (including not regulating at all) and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective.
- The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
- Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
- Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.
- Consider including examples of how the proposed rule would impact you negatively or positively.
- Comments on the economic effects of rules that include quantitative and qualitative data are especially helpful.
- Include the pros and cons and trade-offs of your position and explain them. Consider other points of view, and respond to them with facts and sound reasoning.
Apply for an ISHE Scholarship by April 1st
Is your child attending college this fall? In 1997, the ISHE Scholarship Award Program was established. ISHE will award up to two scholarships per school year, one earmarked for the Northern District, and one earmarked for the Southern District. These scholarships are available to the sons, daughters, grandsons and granddaughters of ISHE members who are attending college and majoring in an engineering or technology discipline.
During each Spring State Meeting, a motion may be presented on the floor for two scholarships of $2,000.00 each to be transferred from the General Fund into the Scholarship Fund for the coming year. Apply by April 1st.
See the ISHE Scholarship FAQ and apply.
Learn the Latest at the ISHE / Purdue Meeting at
IU Health Arnett on April 18th - 10:30 a.m. - 5:00 p.m.
Join us April 18th for the ISHE meeting at IU Health Arnett in Lafayette. In addition to a full day of educational sessions and speakers, we will take a tour of the IU Heath Arnett facility.
Seminar Overview: The construction and renovation process in health facilities is a never-ending process. Even when construction of new greenfield project may not be on the immediate horizon for a health facility, there is an almost continuous need to change the function of spaces, renew spaces and replace and update infrastructure. Often these activities take place in or adjacent to spaces where patient care takes place.
This seminar will examine several issues regarding construction and renovation, including maintaining compliance, using risk assessment to determine mitigation measures and providing a safe, comfortable and compassionate patient care environment.
This is also a unique opportunity to meet and interact with students at Purdue University who may well be the future leaders in creating and managing the health care physical environment.
RSVP right now at: http://www.isheweb.org/content/rsvp-purdue-2014.php
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