Happy Veterans Day, everybody!

Today, I electronically submitted the attached letter to CMS requesting
an extension to the public comment period for the Claims Attachments
Notice of Proposed Rule Making (NPRM). After uncounted hours of
back-and-forth reading, analyses, and writing [around 70 pages of
comments so far], I just didn't have sufficient time to get through all
the materials. I think my letter summarizes my position succinctly.

Based on information from about a week ago, it appears that the
possibility of a Claims Attachment NPRM public comment period extension
remains under consideration by CMS/OESS. If they grant one, they've not
yet 'officially' determined how long it will be; nor how soon we'll be
notified. It could be anytime: up to or even after the present
11/22/2005 closing date. Other than continuing to prepare what comments
we have time for, all we can do at this time is watch the Federal
Register -- and perhaps the Office of Management and Budget for an
earlier indication that an extension Notice is in process.

In the meantime, I've asked for more time. Any feedback is welcome.

Dave Feinberg
Rensis Corporation [A Consulting Company]
206-617-1717
DAFeinberg@...
Author of "Understanding HIPAA Communications"