What Needs to Be Done

The specific action steps for a policy initiative will vary, depending on several factors, including the issue, the locality, and established procedures for writing regulations and obtaining comments. It also may be shaped by the presented earlier in the Policy Action Guide. When trying to affect policy through regulations, however, there are certain general steps that should be incorporated:

Obtaining Input and Building Support

Before developing your comments and recommendations for the regulations, it will be valuable to collect input from a variety of stakeholders and populations that may be affected by the legislation to understand varying perspectives. Given the short timelines for submitting comments, input will usually need to be gathered quickly.

Important considerations for obtaining input and building support for regulations include:

  • How will you let various stakeholder groups know about the opportunity to provide comments on the regulation?
  • How will you solicit and incorporate input from populations that will be affected by the legislation (e.g., youth, family members, community members)?

Resources

Building Community Support
Child Welfare Information Gateway

The Community Toolbox
University of Kansas, Work Group for Community Health and Development
See Part B, which includes information about obtaining input from stakeholders; Part C, which provides information about promoting interest in community issues and encouraging the involvement of diverse groups; and Part I, which includes information about using the media to promote a cause.

Leadership in Systems of Care: Creating and Communicating a Shared Vision (PDF - 565 KB)
National Technical Assistance and Evaluation Center for Systems of Care

Systems of Care Infrastructure Toolkit: Communication
National Technical Assistance and Evaluation Center for Systems of Care

Systems of Care Infrastructure Toolkit: Strategic Planning
National Technical Assistance and Evaluation Center for Systems of Care

Use of Communication in Quality Improvement
Child Welfare Information Gateway

Using Advocacy to End Homelessness: A Toolkit for Understanding and Conducting Advocacy (PDF - 20,170 KB)
National Alliance to End Homelessness

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Developing the Recommendations

Carefully crafted regulations are a core component of implementing legislation. The foundation for your comments can draw from multiple sources, such as stakeholder input or a review of similar policies or procedures. The comments could be questions about what is currently written or recommendations about how the text should be written.

Important considerations for developing your comments include:

  • What are the most critical points to convey in your comments?
  • Have you considered the consequences of each recommendation (e.g., cost, effect on your staff, and children and families you serve)?
  • What information or data will be required to support your recommendations?
  • Have you reviewed regulations related to similar legislation in other jurisdictions for ideas about successful methods of implementation?
  • Will each partner submit its own set of comments, or will the group submit one unified set? Who will take the lead in drafting the comments? Who in each partner organization will need to review and sign off on the comment submission?

Resources

Final Rule by the Administration for Children and Families on the Chafee National Youth in Transition Database (PDF - 287 KB)
U.S. Department of Health and Human Services, Administration for Children and Families
Example of the types of comments provided on legislation and the agency responses.

How to Effectively Comment on Regulations (PDF - 153 KB)
The Brookings Institution

Policy Matters: Setting and Measuring Benchmarks for State Policies (PDF - 1,567 KB)
Center for the Study of Social Policy

Regulations.gov
Federal website that allows users to search, review, and comment on Federal regulations.

Systems of Care Infrastructure Toolkit: Policy
National Technical Assistance and Evaluation Center for Systems of Care

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Planning Outreach and Development Strategies

An effective outreach strategy will encourage buy-in and involvement of stakeholders in the development of your comments and also support education efforts after the final regulations are released. A concerted effort among many stakeholders, both internal and external to your organization, can be an effective approach to affecting the final regulation. In addition, some thought should be given to how the proposed regulations may require changes in work processes and skill requirements and the potential implications for training, coaching and supervision, data systems, and administrative practices. Important considerations for developing an outreach strategy include:

After the final regulation has been approved, how will you communicate the new regulations to staff and other stakeholders (e.g., staff meetings, e-mail, newsletter article)?
What changes within your organization will need to be made if the proposed recommendations are included in the final regulations by the government agency? For example, what types of training or other professional development will be required? What changes, if any, will be needed for staffing and recruitment? Coaching and supervision? Data or administrative systems? Manuals or forms?

Resources

The Community Toolbox
University of Kansas, Work Group for Community Health and Development
Chapter about how to institutionalize an initiative.

Gaining Buy-in From the Front Line During Times of Change (PDF - 439 KB)
National Technical Assistance and Evaluation Center for Systems of Care

Implementation-Specific Tools and Resources
California Evidence-Based Clearinghouse

Improving Child Welfare Outcomes Through Systems of Care: Building the Infrastructure: A Guide for Communities 
National Technical Assistance and Evaluation Center for Systems of Care
View Abstract and Download

Improving Child Welfare Outcomes Through Systems of Care: Systems of Care Guide: Guide for Strategic Planning (PDF - 4,696 KB)
National Technical Assistance and Evaluation Center for Systems of Care

National Implementation Research Network (NIRN)

The Role of Social Marketing in System Reform
Child Welfare Information Gateway

Systems of Care Infrastructure Toolkit: Communication
National Technical Assistance and Evaluation Center for Systems of Care

Systems of Care Infrastructure Toolkit: Training, Development, and Human Resources
National Technical Assistance and Evaluation Center for Systems of Care

Use of Communication in Quality Improvement
Child Welfare Information Gateway

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Identifying Resources

To participate in the rulemaking process, you will primarily need nonmonetary resources, such as expertise or personal connections. Your team will need a thorough understanding of the legislative and rulemaking process, how to read and interpret the applicable legal documents, and the issue area addressed by the legislation. As you identify the required resources for your initiative, you should keep in mind the partners that will be able to provide them.

Important considerations for identifying and obtaining resources include:

  • What types of resources are needed (e.g., meeting space, knowledge, skills, relationships, funding)?
  • Does your organization need any external assistance to prepare the comments, such as counsel from an attorney?

Resources

Community Partnerships: Improving the Response to Child Maltreatment
U.S. Department of Health and Human Services, Children's Bureau, Office on Child Abuse and Neglect
Chapter 3 provides an overview of how to build and sustain a community partnership, including securing funding and other resources.

The Community Toolbox
University of Kansas, Work Group for Community Health and Development
See Part L, which provides information about generating, managing, and sustaining financial resources, and Part M, which provides information about soliciting contributions and in-kind support.

Effective Financing Strategies for Systems of Care: Examples from the Field: A Resource Compendium for Developing a Comprehensive Financing Plan (PDF - 2,809 KB)
University of South Florida, Louis de la Parte Florida Mental Health Institute, Research and Training Center for Children's Mental Health

Grants.gov
U.S. Department of Health and Human Services

Funding
Child Welfare Information Gateway

Maximizing Program Services Through Private Sector Partnerships and Relationships: A Guide for Faith- and Community-Based Service Providers (PDF - 2,590 KB)
U.S. Department of Health and Human Services, Substance Abuse and Mental Health Services Administration, Center for Substance Abuse Treatment

Systems of Care Infrastructure Toolkit: Finance
National Technical Assistance and Evaluation Center for Systems of Care

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