How to Submit Federal Public Comments

A federal rulemaking comment guide for ophthalmologists.

Federal agencies — CMS, the FDA, HHS, the FTC, and others — propose rules every year that directly affect how ophthalmologists practice. Medicare payment systems, quality payment programs, prior authorization standards, and telehealth coverage policies all begin as proposed rules open to public comment.

Agencies are legally required to read and respond to substantive comments. A short, well-targeted letter from a physician carries unique weight: you bring patient-care expertise that government career staff often lack. This guide will walk you through the process.

How Federal Rulemaking Works

Notice of Proposed Rulemaking (NPRM). An agency publishes a draft rule in the Federal Register and opens a comment period — usually 60 days for major rules.

Public comment period. Anyone — individuals, practices, or societies — may submit written comments through Regulations.gov.

Final rule. The agency reviews comments, responds to substantive points, and publishes a final rule. Substantive comments routinely change the final language; vague form letters rarely do.

Submitting on Regulations.gov — Step by Step

Go to Regulations.gov. This is the federal portal for nearly all agency rulemakings.
Find the rule. Search by docket number (e.g., CMS-1807-P for the 2026 Medicare PFS proposed rule) or by keyword ("Medicare Advantage," "prior authorization," "physician fee schedule"). The Academy usually publishes docket numbers in advocacy alerts.
Confirm the deadline. Look for "Comments Due" at the top of the docket page. Submissions received even one minute late are not accepted.
Click "Comment." A form opens. Paste your comment into the text box or upload a PDF or Word file — recommended for anything longer than a few paragraphs, as formatting and citations survive better.
Fill in identity fields. Enter your name, credentials (MD/DO), city, state, and the category "Individual" or "Health Professional." If commenting on behalf of a practice or society, choose "Organization" and name it. You may comment anonymously, but signed physician comments carry far more weight.
Review the privacy notice. Everything you submit — including your name and any attachments — becomes part of the permanent public record and is searchable online. Do not include PHI, home addresses, or any patient identifiers.
Submit and save your confirmation number. You will receive a tracking number and an emailed confirmation. Save both. Comments typically appear publicly on the docket within a few business days.

Writing an Effective Comment

Agency staff weigh comments by substance, not volume. One well-reasoned page from an ophthalmologist outperforms a thousand identical form letters.

Aim for a structure roughly like this:

Opening (2–3 sentences). State who you are, the docket number, and whether you support, oppose, or want specific policies within the rule to be changed.
Credentials. One sentence on your specialty, years in practice, and patient volume. Example: "I am a comprehensive ophthalmologist in solo practice in Toledo, Ohio, treating 400 Medicare beneficiaries per year."
Specifics. Reference policies as specifically as possible. Agencies must respond to specific objections; they may ignore generalized opposition. Example: "I am opposed to the -2.5% efficiency adjustment to non-time-based codes" is much stronger than "I am opposed to the payment cut."
Clinical evidence. Standard of care, complication rates, MIPS measure performance, the practical implications for surgical scheduling — anything quantitative or patient-grounded that agency economists cannot see from their data sets.
A concrete alternative. "Instead of X, the agency should adopt Y because…" Suggested fixes are far more persuasive than complaints.
Close. Restate your position in one sentence and thank the agency for considering the comment.

Dos and Don'ts

Do	Don't
Write in your own words. Original language counts as a unique comment. Identical copy-and-paste letters are bundled and counted once.	Don't submit a form letter unedited. If the Academy provides a template, change the opening, add a personal example, and rewrite at least one paragraph.
Be as specific as possible. Reference the exact policy or code you are addressing. Academy advocacy alerts can help identify the policies of greatest concern.	Don't argue policy in the abstract. "CMS should value our work more" goes nowhere. "The proposed work RVU of 8.20 for CPT XXXXX underestimates physician work by…" goes somewhere.
Use data when you have it. Volumes, administrative staff time, complication rates, MIPS scores — anonymized and aggregated.	Don't include PHI. Never name a patient, share an MRN, or describe a case in identifiable detail. Comments are public forever.
Stay professional and specific. A measured, fact-based tone is the most persuasive register with career civil servants.	Don't be hostile, sarcastic, or partisan. Personal attacks on the agency or the administration are routinely flagged and discounted.
Submit early. Regulations.gov has been known to slow or crash in the final hours of a comment window. Aim to file at least 48 hours before the deadline.	Don't wait until the last day. Late submissions are rejected automatically. There is no grace period and no appeal.
Coordinate, don't duplicate. Check what the Academy, your subspecialty society, or your state society have said. Add to their points with your own clinical lens instead of restating them.	Don't sign on to letters you haven't read. Mass-signed letters are weighed as a single comment. Your individual letter carries more weight than your name on someone else's.

Pre-Submission Checklist

Before you submit, confirm:

Position (support / oppose / modify) is clearly stated in the first paragraph
At least one ophthalmology-specific clinical example or data point is included
A concrete alternative or recommended fix is proposed
No PHI, patient identifiers, or sensitive personal information is included
Name, credentials, city, and state appear at the close
Submitted before the deadline and confirmation email is saved