* Note the specific page and paragraph in a rule that pertains to an issue being discussed in the comment.
* Be brief, focusing on areas that really matter and especially where regulators ask for comment.
* Use concise rationale in explaining an issue, especially if correcting a factual error in the rule.
* Don't complain. In every area of concern, give an alternative proposal that will meet regulators' policy goals.
* Skip a lot of theory. Combine comments with suggestions backed by factual support and real-life examples of actual problems.
Compiled by Bill Bernstein, a partner and chair of the health care division at New York law firm Manatt, Phelps & Phillips; and Erica Drazen, managing director of the healthcare group at Computer Sciences Corp., a Falls Church, Va.-based technology and consulting firm.
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