Action Alert: Tell Obama Administration 30 days not enough to comment on 700 pages of regulations

12/18/2012 - 1:05pm

Tell the Obama Administration to extend the comment period for four Obamacare regulations to 60 days. The Administration has given the public only 30 days for the public to comment on them. These four regulations (listed below), consist of 745 pages (125,612 words).

We've already submitted our comments protesting this unusually short comment period. In fact, 10 of 18 comments submitted on one of these regulations (HHS Notice of Benefit and Payment Parameters for 2014 [as of December 17, 2012]) ask the Obama Administration to give more than just 30 days to comment.


  1. Read our talking points.
  2. Click the Comment Now button for each regulation. This will take you to the appropriate form where you can tell the Obama Administration to extend the deadline.
  3. Important: Remember that any information you submit becomes part of the public record, so don’t submit your name or address unless you want everyone to be able to see it. The Name fields are typically required, but it’s perfectly acceptable to write “Anonymous.”

Talking Points:

  • The 30 day comment periods ignores Sec. 6(a)(1) of Executive Order 12866 which states in relevant part:
    In addition, each agency should afford the public a meaningful opportunity to comment on any proposed regulation, which in most cases should include a comment period of not less than 60 days. [Emphasis added.]
  • None of the regulations explain why they chose not to follow Executive Order 12866's default 60-day comment period
  • Americans were deluged with Obamacare regulations just a couple of weeks after the election. Thirty days is not long enough to properly review and respond to their contents. There are seven Obamacare regulations open for comment--all published within a two week period. The four that have 30-day comment periods are due as early as the day after Christmas and as late as January 4, 2013
  • The comments for these regulations are due in the middle of the holiday season when many Americans are focused on family and friends and when businesses are short-staffed due to vacationing employees.
  • Two of the regulations ("Health Insurance Market Rules, Rate Review" and "Standards Relating to Essential Health Benefits") were completed in early August and could have been published for public comment much sooner.

The Regulations:

Comment Now! Health Insurance Market Rules; Rate Review
Comment Period Ends: December 26, 2012 - 5:00pm

Comment Now! Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation
Comment Period Ends: December 26, 2012 - 5:00pm

Comment Now! HHS Notice of Benefit and Payment Parameters for 2014
Comment Period Ends: December 31, 2012 - 5:00pm

Comment Now! Establishment of Multi-State Plan Program for Affordable Insurance Exchanges
Comment Period Ends: January 4, 2013 - 11:59pm