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Public Comment for Topics Under Discussion

Health Evidence Review Commission Opportunities for Public Input

 
The Health Evidence Review Commission (HERC) and its subcommittees are public bodies that accept public comments related to discussion topics. Advisory panels, task forces and work groups also meet from time to time to bring together experts on particular topics such as genetics, behavioral health or dental health. To ensure an orderly process, the Commission has developed these policies for accepting public comment. As you prepare your comments, you may wish to review the HERC's Quality of Evidence Statement to better understand the Commission's standards for evaluating evidence.
  
HERC follows the same process for most public meetings (on rare occasions, the commission or a subcommittee may meet without offering opportunity for public comment; in these cases, comments will be accepted at other meetings on the same topic).
 
The typical process involves a staff review of the evidence around the health service in question. HERC Staff presents recommendations to the Value-based Benefits Subcommittee, which may then request further research or make a recommendation to the HERC to revise the prioritized list. Typically, VbBS and HERC meetings are on the same day, and recommendations made by the VbBS in the morning are reviewed by the HERC the same afternoon. In addition, for topics related to a coverage guidance or multisector interventions report, there are additional opportunities for public comment--in person at EbGS or HTAS meetings, and during the formal written comment period. 

Comments related to any public meeting discussion topic

  

Includes comments related to Coverage Guidances (except formal comment periods) and Prioritized List issues

 

Written comment prior to a meeting
 
Unsolicited written comment (up to 1,000 words) submitted by email to herc.info@state.or.us at by noon Pacific time on the Tuesday prior to a Commission or subcommittee meeting will be forwarded to the Commission or subcommittee members. Staff and subcommittee members may or may not choose to discuss the comment at the public meeting. Comments related to a Coverage Guidance and associated Prioritized List changes will be evaluated as described above.
 
Comments submitted after the deadline will be rejected, but submitters may submit them prior to a subsequent meeting.
 
Verbal comment at a public meeting
  
Verbal comments are accepted at almost every HERC and subcommittee meeting. (The only exception is for public meetings discussing a topic which have had or will have extended opportunity for public comment at another meeting.) At meetings where public comment is accepted, any member of the public or group may provide verbal comments when invited by the chair. Due to time constraints, such comment may be limited by the chair to five minutes per topic (shared among all those who wish to testify). Commenters are encouraged to sign in or notify staff they wish to testify and to bring 15 copies of their complete testimony in written form. They should also be prepared with one- and three-minute highlights of their testimony in case time is limited. Comments related to a Coverage Guidance and associated Prioritized List changes will be evaluated as described above.
  
Solicited testimony
  
HERC may solicit written or verbal expert testimony on topics of interest to the Commission. When requesting such testimony, HERC staff will inform the expert of the meeting date, the time available for testimony and materials desired.
 
 
Comments on evidence-based reports (coverage guidances/multisector intervention reports)
  
Evidence-based report formal comment periods
  
For these in-depth reports, HERC strongly prefers that comments be submitted during the formal written public comment periods, which are announced publicly via our e-Subscribe service. Submitting comments to herc.info@state.or.us during the formal written public comment period ensures that your comment, and any accompanying evidence, will be formally evaluated and receive a written response. For more information, see our coverage guidances open for comment page and our overview of the Coverage Guidance development process.
 
  
Evidence-based reports (outside formal comment periods)
 
You can submit comments according to the “Written comment prior to a meeting” or “Verbal comment at a public meeting” sections above. Decisions on whether and how to incorporate the comments will be made based on our policy for Consideration of Evidence Discovered After Formal Comment Period.
 

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