Comment on FR Doc # 2010-11214

RE: Issues and Questions To Be Resolved (item 12) "How can the new methodology be implemented in a manner that minimizes disruption and assures equity to the various areas affected?" -- We recommend that this issue be expanded to include, how policy can accommodate the transition from old methodology to new; perhaps to include a "hold harmless" process for a period of time. Additionally, this item should be an early, if not first priority for resolution among the negotiation participants. RE: Affected Interests and Potential Participants. -- Primary Care Offices (PCO) are the primary state level implementers of designation policy. Limiting PCO negotiation participants to three representatives is unlikely to sufficiently reveal every variation on the application of designation policy among the 54 state and territorial PCOs. Furthermore, three PCO representatives are out of balance with the approximately eight representatives who are explicit stakeholders in the outcome of any designation determination. We recommend expanding PCO representation to five. RE: Affected Interests and Potential Participants. -- I wish to submit my name for consideration as a PCO negotiation participant: Stephen Holloway, Director, Primary Care Office, Colorado Department of Public Health and Environment, 303-692-2582, steve.holloway@state.co.us