In recent years, the government has also become more forthcoming about what kinds of public comments are more likely to have an impact on regulators as they develop their final rules and policies. In 2018, experts at the National Institutes of Health (NIH) put out “The Insider’s Guide to Effective Commenting on NIH Policies.” The guide emphasizes that submissions that offer comments on specific areas of note, as opposed to a submission of general support or opposition, are more likely to be utilized by federal agencies. For instance, how will the area of concern impact you as an IRB or IACUC? Even if you only have positive things to say, you should still consider submitting comments: regulators can use them to justify advancing their proposed regulations and policies onto the next step. In the alternative, if you’re interested in changing the proposed regulation or policy, consider offering practical suggestions regulators can feasibly implement, like wording changes to proposed policies or asking for additional guidance. When it comes to regulatory policy, “boring” suggestions can be a good thing!
The government also suggests specifying the exact issues you are concerned with, down to the page number/paragraph/phrase, etc. (if possible). This will make it easier for regulators to be responsive to your precise concern. You may also endorse or provide feedback on comments that have already been submitted by other parties. If you choose this approach, you should include the comment ID to allow regulators to more easily cross-reference them. You should also note your credentials or experience (e.g. IRB chair) to help set apart your comments from the others (though keep in mind that comments submitted to the government ultimately become public).