Input on Proposed Updates to the IRP Supplementary Procedures

Rule 3 - Panel Selection

Support: Yes

Comments: The proposed changes to Rule 3 ensure a more transparent and fair process for panel selection. The updates provide clear guidelines that enhance the independence and impartiality of panel members, which is crucial for maintaining the integrity of the Independent Review Process (IRP).

Rule 4 - Time for Filing

Support: Yes, with recommendations

Comments: The changes to Rule 4 are comprehensive, but there are some concerns:

4A – Initiation of an IRP: The initiation period is reasonable and ensures claimants have sufficient time to prepare their cases.

4B – Time to File: The time to file seems adequate, but an extension might be necessary in complex cases.

4C – Timing considerations for a Claimant to File an IRP following a Request for Reconsideration (RFR): This is a valuable addition, offering clarity and ensuring that claimants have a clear timeline.

4D – Limited Circumstances for Requesting Permission to File After the 24-month limit: This provision is necessary, but it should be clearer about what constitutes "limited circumstances" to avoid ambiguity.

Rule 5B - Translation

Support: Yes

Comments: The requirement for translation in Rule 5B is essential to ensure that all parties, regardless of language, have access to the IRP. This update promotes inclusivity and fairness in the process.

Rule 7 - Consolidation, Intervention, and Participation as an Amicus

Support: Yes

Comments: The changes to Rule 7 are well-founded, as they provide a structured approach for consolidation and intervention. Including provisions for participation as an amicus curiae enhances the process by allowing expert input, which can be valuable for the panel’s decision-making.

Overall, I support the proposed updates to the IRP Supplementary Procedures. They enhance transparency, inclusivity, and fairness in the Independent Review Process. However, some aspects, particularly in Rule 4D, could benefit from further clarification to ensure consistent application. I appreciate the opportunity to provide input and look forward to seeing the final updates based on community feedback.

The attached document provides detailed feedback on the proposed updates to the IRP Supplementary Procedures. This includes comments on Rule 3 (Panel Selection), Rule 4 (Time for Filing), Rule 5B (Translation), and Rule 7 (Consolidation, Intervention, and Participation as an Amicus). The feedback supports most of the proposed changes, with specific recommendations for clarifying certain aspects, particularly in Rule 4D. The document is intended to supplement the Public Comment Proceeding form by offering a more in-depth analysis of the proposed rules.

This submission supports the proposed updates to the IRP Supplementary Procedures, with some recommendations for improvement. The changes enhance transparency, inclusivity, and fairness in the Independent Review Process. Key observations include the need for clearer guidelines in Rule 4D regarding limited circumstances for filing after the 24-month limit, and support for translation requirements to ensure inclusivity. The submission reflects a positive stance on the proposed updates, emphasizing the importance of maintaining a fair and independent review process.