Making Your Voice Heard - HOW YOU CAN PARTICIPATE

Making Your Voice Heard
PUBLIC COMMENT DEFINED, HOW YOU CAN PARTICIPATE—AND WHY YOU SHOULD

13November–December 2007
UNOS Update
BY KAREN SOKOHL

Did you know that the OPTN/UNOS policy development
process includes an opportunity for the transplant
community and the general public to review and comment on
new policy proposals?
If you didn’t, you’re not alone.
Last December, nearly 3,000 transplant professionals
responded to a UNOS questionnaire, and 56 percent of
respondents said that they’d never participated in the public
comment process —and an additional 7 percent indicated
that they weren’t even aware of how to do it.
It’s easy for you to share your opinion —we’ll show you
how —it’s your right (and perhaps, your responsibility).

A policy proposal is born

Policy proposals typically begin at the committee level.
Sometimes the board will charge a committee to pursue a
particular issue in depth. Other times, committee members
themselves are responding to any number of topical issues,
from changes in clinical practice to deficiencies in the system
or simply an exploration of a new concept.
Before committee ideas for changes in transplant policy go
any further, however, interested parties have an opportunity to
weigh in. Federal law actually requires that the transplant
community and the general public have a way to express their
opinion about all new proposals.
(Some exceptions do apply, of course, if a policy requires
immediate action to ensure public safety or if the change is
simply a correction and not a substantive change in content.)

Soliciting input on the proposal

UNOS informs the community of the opportunity to comment
by sending e-mails, posting alerts on the OPTN and UNOS
websites and including the information as appropriate in the
Update. Generally, 30 to 60 days are allowed for submitting
comment on a proposal.
In addition to gathering input during that time from the
transplant community —including physicians and OPO and
transplant center professionals —UNOS committee liaisons
solicit feedback from each OPTN/UNOS committee, and
UNOS regional administrators solicit feedback from
participants at regional meetings. When the comment
period closes, the committee initiating the proposal reviews
every comment.
Frequently, committee members will modify elements of
their original proposal, based on the comments they’ve
received, and it is only after those modifications are made
that the committee submits the proposal for review to the
OPTN/UNOS board of directors.

A recent example

The public comment response for a
recent bylaw proposal made by the OPTN/UNOS living donor
committee provides a perfect example. The initial proposal as
drafted by the committee included the minimum criteria that
centers must meet if they wish to be designated as a “living
donor transplant center.”
During the comment period, the community submitted
that the bylaws should be more closely aligned with
Medicare’s Conditions of Participation (COP) for Medicare-
approved programs. Some of those who commented also
viewed a few of the guidelines as being too prescriptive and
as dictating medical practice.
In response, the committee changed the language so
that the proposal more closely aligned with Medicare’s COP.
In addition, the committee removed the requirement for
vascular and biliary imaging, making the radiographic
assessment less prescriptive.

A series of intentional steps

“The public comment period is one small part of the entire
policy development process,” explained Deanna Parker, UNOS’
public comment coordinator. “The process is intentionally
designed to allow for deliberate discussions and conscious,
measured decisions.”
Although some feel that the comment period slows down
policy development, it is a critical and necessary component.
It’s also your opportunity to be part of the solution.
“We wouldn’t want to change policy without input from the
public and transplant professionals,” Parker continued. “Public
comment is vital to effective policy development and to
avoiding of unintended consequences.”
When a proposal is ready for public comment, UNOS
notifies interested members by various means, including
e-mail. If you would like for UNOS to add you to the
notification list, send an e-mail to publiccomment@unos.org.
Don’t have computer access? Request a printed copy by
calling (804) 782-4963. You can also call this number if you
currently receive a paper copy and no longer require one.
For more information, visit optn.org (policies > public
comment) or unos.org (what we do > policy management >
public comment).

Karen Sokohl is UNOS’ member communications specialist and a
contributing writer.