Comment on FR Doc # 2012-15537

The proposed period between publication date and effective date is much too short. These regulations, which are quite complex and which are significantly different than prior guidance, are intended to become effective for taxable years beginning on or after the date published as "final or temporary". Hospitals are told they can rely on the proposed regulations until final or temporary regulations are issued, which means they are effective July 1 for many hospitals. Agency commentary indicates you believe this is not an undue burden. This is not true. Especially for those entities with years that begin soon after publication compliance for the entire fiscal year will be difficult or impossible. Policies and procedures will need to be analyzed and re-drafted, automated collections systems will need to be changed, and communications need to be created and disseminated. In addition, for many hospitals there are one or more board committees which will need to review and recommend changes in policy to the full board before management can take any of these actions. To reasonably allow hospitals to comply with these changes, you must provide for at least a 9-month implementation period following publication of final or temporary regulations, and preferably a year implementation period, so that hospitals can have adequate time to develop and gain approval of compliant policies, to redesign, test, and fully document the necessary changes to their automated systems and the procedures their staff members follow, and to develop and deploy the required communications of these changes.