We object to the guidance document should not be in effect June 15th with the public comment period ending July 22nd. The short time period to ensure effectiveness is unreasonable and unrealistic. 

24 hour and 48 hour deadlines: We object to the requirements of 24 & 48 hour deadlines which places extra unfunded administrative burden on providers. The administrative burden for providers to collect, analyze, and report updates may be delayed in collecting the necessary information. Recommendation: Instead of the 24 hour reporting requirement in CHRIS, we propose 2 business days for reporting so that providers can collect necessary information to include in the CHRIS system. We also object the 48 hour time period to update the CHRIS system with additional medical information. Gathering outside medical information is out of the control of the provider and remains at the mercy of the outside entity to provide the requested information.

Two year time frame: We object to the two year time frame as no definition in the document as to when the two year time frame begins: calendar, fiscal, or an arbitrary date for each provider. The focus should be placed on improving care on the individuals we serve.