AMIA's Tips for Compiling a Response

Preparing Input to AMIA Comments in Response to Proposed Rules and Regulations: Tips and Pointers

1. The drafting of regulatory comments is best thought of as a relatively 'technical' process. This is not the time to 'argue' with the underlying legislation or wax either poetic or emotional. Regulations are usually about 'facts and data' and so too should comments be.

2. Marshall Facts: Your argument—and you are making an argument—must be supported by facts. Don't copy and paste paragraphs of pre-written text from letters, blogs, or others' documents. Don't misrepresent your position - decisions should be based on sound data and accurate facts.

3. Clearly state your suggestion/position/request: Be specific. Clearly illustrate your support or opposition for the regulations.

4. Give examples to back up or support your comments. Personal experiences are particularly effective, and often moving. Share them!

5. Typically an AMIA comment will use real-life hospital or practice examples, of course, but its tack will be aimed more at influencing 'good' HIT policy than at 'correcting' regulatory errors that would have specific impact on particular stakeholders. Look especially at topic items for which the Department has requested comments.

6. Distinguish between parochial comments that might be offered by you as an individual, or you as an employee of a particular organization (relating to Medicare fee schedules for instance), from comments that might better reflect AMIA's position as a thought-leader on HIT and the uses of health information. Such parochial concerns can be addressed separately by you as an individual, on your organizational letterhead, but should not be part of the AMIA commentary.

7. To the extent possible, make your comments specific and detailed; don't say, 'these 23 meaningful use criteria are too ambitious', but rather say something like 'this specific measure may be gatherable in the hospital setting, but would be problematic in the outpatient setting for the following reason(s)…'

8. Use non technical words and avoid jargon or complex medical or technical terms. Cite the specific sections of regulations when commenting about them.

9. Try not to develop your input based only on other people's summaries or news reports of what the regulations say.

10. Try not to cherry-pick words or phrases here and there; there are many tables in the draft regulations that briefly lay out the proposed criteria and standards – it may be particularly useful to provide input based on those.