N001298
Pre-Conference
As I recall Mr. Feinberg's comments on PBS he
indicated that he wanted the beneficiary to know, with
a fair degree of accuracy, the benefits they would
receive under the program. To this end he mentioned
that there would be a right to come into his office
and discuss the matter before submission of the actual
claim form.
The proposed regulations do not make provision for a
pre-submission conference. A pre-submission conference
is extremely important to my client as they have
special circumstances that would not normally be
addressed in a typical application and the proposed 21
days to file supplemental information may not be
sufficient time to develop the data. If a
pre-submission conference were held it would be
possible to submit data appropriate from the Master's
viewpoint in the original claim. Specifically, my
client has a child that is severely mentally impaired
but not legally incompetent. Guidance from the Master
regarding what would help him understand our position
may not be possible to obtain in the 21 days allowed
by the current regulations to file supplementary
information.
Individual Comment