The EACH/PIC Coalition submitted a comment letter to the Maryland PDAB, providing input on the board’s cost review rulemaking procedures.
The letter stated:
“We appreciate the board’s decision to extend the public comment period for the proposed rulemaking on changes to the cost review process. However, this extended timeline remains an exception rather than the standard.”
“The board has too often advanced rulemakings with only a 14-day comment period, which effectively provides stakeholders with 10 business days or fewer to review complex proposals and develop meaningful feedback. We have long urged the board to adopt a minimum 30-day comment period for all rulemakings and continue to encourage the board to establish that standard moving forward.”
“We also appreciate the opportunity to learn more about the proposed changes during the upcoming meeting. Additional discussion of the proposed rule, the rationale behind the changes, and staff recommendations will help stakeholders and board members alike engage more meaningfully in the process and provide more informed feedback.”