1. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 The Regulation Process and Beyond: Commenting on the Birth Certificate Regulations

2. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Philosophy of Regulation Development To maintain a state-based birth registration and certification system with ownership of the data remaining with the states. To make a more secure, timely, responsive birth registration and certification system and specifically to improve security of collection, handling & issuing of birth certificates.

3. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Philosophy of Regulation Development To make a more connected birth certificate system Improve the flow of information within and between states and between the states and the Federal Government. No death certificate regulations except as necessary to make birth certificates more secure

4. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Status of Regulations Initial DHHS review completed in 2006 Modifications completed in early 2007 Revised regulations sent to CDC and HHS reviews in May 2007 Next step---OMB review Later—Public review

5. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Public Comments Who should comment---Everyone !! (“Consensus” comments as well as the “maverick” comments) 60 day public review period

6. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Public Comments Electronic access----- www.Regulations.gov www.Regulations.gov Through this website: Enter your comments Review the comments of anyone else Enter new comments based on your review of other’s comments

7. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Public Comments What to be commented on: Preamble Regulation Economic analysis Comments received will be reviewed and summarized. Summarization to be included in the revised NPRM

8. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Other Methods for Commenting Other ways to provide comments Emails to NCHS Written letters Telephone calls Personal conversations All comments received will be entered into www.regulations.govwww.regulations.gov

9. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Other Methods for Commenting Reading Room to be created at NCHS Reading Room Capabilities Assess the internet Submit comments Review comments submitted Make copies of comments

10. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Other Methods for Commenting These “other methods” are not the preferred approach!!

11. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Most Helpful Comments Identify the specific regulation Explain the reason for any change Provide the recommended change Include supporting data, with proper documentation

12. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Privacy of Comments All comments are public Exception is Proprietary or confidential business information, which must be: Delivered by mail directly to NCHS. Clearly marked as proprietary Will not be placed in public file, but a note about its receipt will be Subject to the Freedom of Information Act. Case-by-case decision.

13. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 After Comment Period………. Summarize all comments received Produce a report of the summarized comments Revise the preamble, regulations and/or economic analysis based on comments Submit revised draft for internal review

14. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Internal Review Process NCHS/CDC---about 30 days DHHS---from 30 to 60 days OMB----90 days

15. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 Implementation Release approved regulations in the Federal Register 30 days after this release, the regulations become effective Clock begins!

16. The NAPHSIS/NCHS Collaboration Past Successes and Future Challenges Salt Lake City, UT June 3 rd – 7 th, 2007 In Closing Not everyone will agree with everything stated---none of us will agree with everything. Note your differences along with the reasons and supporting data. Be “open” to change