You send us your thorniest research communications questions and we answer them.
Dear PRB,
I’ve heard colleagues mention that they’ve submitted comments on federal policies and programs, but I don’t know where to start. And why should I bother—does anyone even read the comments that come in?
Signed,
Chatty Cathy
_______________
Dear Chatty Cathy,
We’re so delighted that you’re interested in sharing your expertise! While there are many ways to engage in federal decisions on topics ranging from survey methodology to funding programs, the Federal Register is often the place to start.
What is the Federal Register, you ask? GovInfo describes the Federal Register as “the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.” Many hearings and meetings are also announced in the Federal Register. For our purposes, think of it as the place where calls for public comment get posted.
Because it covers all of the federal government, a single issue of the Federal Register may be several hundred pages. Thankfully, you can sign up for notifications on topics that interest you, so you don’t need to scan hundreds of pages each day to stay informed. Professional associations may also send out action alerts when there’s a topic of interest.
Federal comment opportunities fall into a couple of categories:
- Proposed rules, such as changes to motor vehicle safety standards or citizenship eligibility.
- Requests for information, such as a recent call for input on AI and Open Government Data Assets.
- Notices of call for comment, such as a recent notice on American Community Survey Timeline for Implementing Updated 2024 Race and Ethnicity Data Standards.
- Notices of submissions by federal agencies to the Office of Management and Budget for data collection approvals, such as Centers for Disease Control and Prevention’s Needle Exchange Utilization Survey.
Each Federal Register Notice (FRN) will include information about the topic or proposed change along with information about how to respond (often by sending communication to an email address by a given due date).
As for what to write, tone and content are a personal style choice. But a few strategies to consider when responding to an FRN are the following:
- Be as concrete as possible about the costs/benefits of what you’re suggesting. For example:
- Will the change improve survey response rates?
- Will it better identify characteristics of a population of interest?
- Will it better align with international standards or better reflect local community concerns?
- Will the proposed change be harmful to a community, and thus should be reconsidered?
- Citations aren’t strictly necessary but can be helpful. At a minimum, your comment should include information that establishes your research expertise.
- In a 60-day comment period for data collection, suggestions for survey question wording and methodological changes are not just ok, they’re encouraged.
One very important note: Anything you submit in response to a FRN is part of the public record. That means your comments are searchable and readable by anyone. So keep that in mind as you type.
And to address your final question: Why bother?
While the federal government may seem like a bureaucratic morass to anyone outside of Washington, D.C., the truth is that federal agency staff are eager for public input. Comments can and do result in changes to federal programs and policies. For example, in response to public feedback, the U.S. Census Bureau recently changed their plans on revising disability questions in the American Community Survey.
Agency staff also use comments to identify key stakeholders and experts to include in future efforts such as workshops and convenings, special studies, and more.
In short, even though not every comment will be incorporated into the final plan or product, many do. Comments matter.
Happy commenting!
Sincerely,
Ask PRB
P.S.
For a video walk-through of the process, you can watch Responding to Federal Requests for Comment.
This article was written by Beth Jarosz, Senior Program Director in U.S. Programs at PRB.