The importance of commenting on proposed changes to regulations

Britta Gustafson
November 15, 2022

Song Sparrow, Seedskadee National Wildlife Refuge (Tom Koerner; U.S. Fish and Wildlife Service), CC-BY

A1M recently submitted our first comment response to a Notice of Proposed Rulemaking from CMS related to the Medicaid program and the Children’s Health Insurance Program (CHIP), suggesting improvements for implementation of eligibility and enrollment changes.

Why we’re excited to participate

Commenting on proposed changes to Medicaid and CHIP regulations is a meaningful, concrete way to contribute to improving the programs. The regulatory notice-and-comment process is open to the public, and CMS is obligated to read all comments from the public, evaluate their arguments, and consider them as part of writing its final rule. They must also respond to all the comments in the aggregate in the final published rule.

This comment process is an important way for CMS to receive specific input from anyone with an interest or stake in its regulations, including advocacy organizations, individuals enrolled in the programs, healthcare providers, academics, state and local governments, and companies large and small.

We believe that teams with experience in both policy and human-centered design should contribute expertise to the development of regulations, so we’re putting that into practice by commenting.

The rule and our comment

This proposed rule is “Streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes”, published on September 7, 2022.

All comments are available to the public, and A1M’s comment is available here. Our team member Rebecca Bruno was the primary author for this comment, with input from Elliot Curry and Heather Brown Palsgrove. We speak about our support for this proposed rule and provide several specific suggestions for improving implementation. Check it out!

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