Submitting Effective Comments

Overview
A comment can express simple support or opposition to a waiver proposal or amendment. However, a constructive, information-rich comment that clearly communicates and supports its claims is more likely to influence FSSA's decision-making process.

These tips are designed to help the public submit comments that will have an impact and assist FSSA policy makers in improving waiver proposals and amendments.

Summary

• Read and understand the waiver or amendment document you are commenting on.

• Feel free to reach out to FSSA with any questions.

• Be concise, but support your claims with evidence and sound reasoning.

• Base your justification on solid evidence, personal experience, or how the proposal may impact you or your community.

• 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 many form letters.

Detailed Recommendations

1. Start Early and Meet the Deadline
   Comment periods close at 11:59 p.m. Eastern Time on the date comments are due. Begin your work early to ensure you can submit a well-crafted comment on time.

2. Understand the Proposal
   Fully understand the issues addressed in the waiver proposal or amendment. If you have questions about any part of the document, reach out to the FSSA contact listed in the notice. Although the agency can help clarify the document’s meaning, your official comment must be submitted through the appropriate comment form.

3. Identify Specific Issues
   Clearly identify the issues within the waiver proposal or amendment that you are commenting on. If commenting on a specific word, phrase, or section, provide the page number, section, and paragraph reference from the proposal document.

4. Focus on Key Issues
   If the proposal covers multiple issues, do not feel obligated to comment on every aspect. Select the issues that most concern you, or those you are most knowledgeable about, and focus your comment on those.

5. Respond to Agency Requests for Information
   FSSA may ask specific questions in the proposal to gather more information. While you can comment on any part of the proposal, consider focusing your comment on these questions or areas where the agency is seeking public input.

6. Provide Constructive Feedback
   Whether you agree or disagree with the proposal, provide constructive feedback. Well-reasoned comments, backed by evidence or real-world experience, are more likely to be influential.

7. Suggest Alternatives
   If you disagree with a proposed action, suggest an alternative and explain how this might achieve the same goals or be more effective. Your alternative should also be based on sound reasoning and evidence.

8. Explain Your Reasoning
   The comment process is not a vote. FSSA is working to formulate the best policy, so when crafting your comment, explain your reasoning in detail. The more thoroughly you support your position, the more likely it will be taken into account.

9. Provide Relevant Experience or Credentials
   If you have personal or professional experience that qualifies you to comment on the proposal, make sure to include this. Whether you're a caregiver, advocate, or healthcare professional, your insights are valuable to the decision-making process.

10. Support Your Comments with Evidence
    FSSA looks for comments that are grounded in sound reasoning and, when possible, supported by scientific data, expert opinions, or personal experience. Use relevant facts and data to strengthen your position.

11. Provide Real-World Examples
    Illustrate your points with examples of how the proposed changes would impact you, your family, or your community, either positively or negatively.

12. Comment on Economic and Social Impacts
    If the proposal could affect costs, services, or other economic or social factors, provide both quantitative and qualitative data to back your claims.

13. Address Trade-Offs and Other Perspectives
    Acknowledge the pros and cons of your position and consider potential opposing views. Respond to these perspectives with facts, sound reasoning, and data to make your position more compelling.

14. Label and Organize Your Attachments
    If submitting more than one attachment, label them clearly using a standardized naming format, such as:

    • Attachment1_<Title of Document>

    • Attachment2_<Title of Document>
      This will help FSSA reviewers quickly identify and review your submissions.

15. Keep a Copy of Your Comment
    Always keep a copy of your comment in a separate file. This will ensure you do not lose your comment if you encounter issues submitting it through the online form.

Posted Comments
After submission, your comment will be processed by FSSA and may be posted for public viewing. However, comments may not be posted if:

• The comment is a mass submission or duplicate.

• The comment is incomplete or irrelevant.

• The comment contains personal information or inappropriate language.

• The submitter requests that the comment not be posted.

Form Letters
While organizations often encourage members to submit form letters addressing common issues, keep in mind that a single, well-supported comment is often more influential than many form letters. FSSA bases decisions on sound reasoning and evidence, not on a majority of form letters.

Disclaimer
This document is intended as a guide to help you submit effective comments; it is not legal advice. If you have legal questions or concerns, seek advice from a legal professional.