The Role of Guidance in Rulemaking

The formal rulemaking process is one issue that we were just talking about that has a very prescribed process. There's a notice in the federal register, usually some advanced notice that a proposed rule will be coming out. That proposed rule comes out and we have a certain amount of time to comment on it. Bonnie, can you talk a little bit about the difference between guidance and a proposed rule? Guidance is something that's very different than the formal rule making process. It often happens when the administration believes that it has the authority to issue some new rules for a certain program without having noticed and comment.