CMS OSORA

Situation

The Office of Strategic Operations and Regulatory Affairs (OSORA) is responsible for the development, coordination, facilitation, and clearance of all the Agency's policy documents. These documents, which include regulations, appear in the Federal Register and serve as operating instructions for health care providers and provider associations. Such regulations are driven by statutory mandates from the Centers for Medicare and Medicaid Services (CMS) and the Department of Health and Human Services (HHS). In order to comply with the health-related requirements of legislation such as the Balanced Budget Act of 1997, the Medicare Modernization Act of 2003, and the American Recovery and Reinvestment Act of 2009, external assistance is needed to complete the regulations required to implement CMS policies. Due to the volume of Federal guidelines, a third party must compose regulations for CMS.

Task

How do you craft clearly written regulations in order to meet the standards of a litany of legislative directives?

Action

HCDI attended planning meetings in which CMS determined policies that should be included in the regulation. Staff members ensured a quality review of a document that reflects the policies and rationale provided by CMS and is written in 12-point MS Word format. In addition, HCDI professionals employed the Federal Dockets Management System to process hard-copy and electronic public comments submitted on the regulations generally within 48 hours of receipt of the comment in FDMS. Most importantly, HCDI utilized personnel with academic and professional experience in regulations writing and development.

Result

HCDI was able to draft successfully a comprehensive and clear regulations document that enables CMS to implement its policies and statutes. HCDI continues to strive for succinct, yet thorough, regulations writing. HCDI values the need for brevity and clarity in the midst of drafting CMS policies and statutes.