10/30/2013
https://www.congress.gov...
"That is one of your recommendations in your report, is that we actually look at written policies as it relates to guidance..."
"It looks like it is a shortcut to changing the rule."
"A guidance should not hurt you, right. A guidance should only help you be able to meet the requirements that are set out in the statute and in the substantive rule process."
"To simply unilaterally, without comment or process, change the rules does not seem to be what a guidance should do."