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 meeting, 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) per agenda topic submitted by email to email@example.com by noon Pacific time two business days before the meeting in question (e.g. the Tuesday prior to a Thursday meeting) will be forwarded to the Commission or subcommittee members. Testimony sent to the Commission's physical office will not be accepted. Unsolicited written comment not related to any topic on the agenda will be limited to a total of 1,000 words per meeting date (in addition to any comment provided on one or more agenda items). Any attachments must be submitted in PDF (preferred) or Microsoft Word formats. 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 exceeding the 1,000 word limit will be truncated. If comments are sent as an email attachment that is not in PDF or Microsoft Word format, staff cannot accept the comment unless it is resubmitted in a correct format prior to the deadline.
Comments submitted after the deadline (noon two business days prior to the meeting in question) will not be accepted, but submitters may resubmit them prior to a subsequent meeting.
Comments submitted will be provided in accordance with this policy to Commission/subcommittee/advisory panel/task force members and are subject to disclosure under Oregon Public Records law. If disclosed because of a public records request, the complete comment will be released including your name and any health information. Only contact information would be redacted.
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.
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.
Everyone has a right to know about and use
Oregon Health Authority (OHA) programs and services. OHA provides free help. Some
examples of the free help OHA can provide are:
you need help or have questions, please contact Daphne Peck at 503-580-9792,
711 TTY or firstname.lastname@example.org at
least 48 hours before the meeting.
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 email@example.com 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. Late comments will be handled according to the "Written comment prior to a meeting" policy as stated above. Evidence submitted with these comments will be incorporated per the Consideration of Evidence Discovered After Formal Comment Period policy.
Evidence-based reports (outside formal comment periods)