Comment on FR Doc # 2013-24094

This is a Comment on the Health Resources and Services Administration (HRSA) Proposed Rule: Change to the Definition of Human Organ under the National Organ Transplant Act

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Comment

Contrary to the claims of the proposed rule, this is a major (economically significant) rule, and would impose costs in lost human lives in the many billions of dollars. The failure of the Department of Health and Human Services to present an honest assessment of regulatory costs (billions), regulatory benefits (zero), and regulatory alternatives (take no action) is completely inconsistent with the commitment of the Obama Administration to honest and transparent regulatory analysis. It violates Executive Order 12866, the Regulatory Flexibility Act, and the Congressional Review Act.

At present, a thousand or more Americans lose their lives every year as a result of a shortage of bone marrow transplants due to a grossly insufficient number of donors under the present voluntary system (see, for example: http://www.ij.org/bone-marrow-statistics.) The use of paid donation is likely to reduce the number of deaths by half or more by increasing substantially both registration and donation. (How substantially remains uncertain, but what is known with certainty is that the present volunteer-only system fails to prevent a thousand deaths a year or more.)

The proposed rule would prevent these potential life-saving benefits. HHS rulemakings in the past have estimated the value of a statistical life (VSL) saved at approximately $8 million. Office of Management and Budget guidance on regulatory impact analysis requires the use of VSL or similar measures when rules have life-saving or life-costing effects. Hence, the proposed rule would impose a cost per year of approximately $800 million dollars per hundred lives lost.

A more detailed set of comments is appended as a PDF file, titled "Becket Bone Marrow Comment."

Attachments

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Becket Bone Marrow Comment

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Comment Period Closed
Dec 2 2013, at 11:59 PM ET
ID: HRSA-2013-0002-0256
Tracking Number: 1jx-891t-2t9u

Document Information

Date Posted: Dec 2, 2013
RIN: Not Assigned
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Submitter Information

Submitter Name: Thomas Becket