ABSTRACT

Government, be it local, state or federal, has the responsibility to provide a framework that reflects the three levels of engagement: laws, which define principles of behavior, regulations, which provide detailed requirements, and guidance, which offers recommended activities/processes. Government employees are not allowed to make any public statements on the notice of proposed rulemaking (NPRM), with the theory being that explaining what one meant by a particular word, phrase or sentence would deter comments, or influence how it should be interpreted. Helping hospitals and physicians plan for the complexities of current and future federal or state regulations requires that the Chief Medical Information Officer (CMIO) have familiarity with the intricate details of these regulations, and there are many misinterpretations of the regulations. The challenges of working in a government agency relate to helping bring a balance of real-world perspective versus the legal requirements of writing rules and regulations.