Get your submission organized before you open the portal
Create a simple document (Word/Google Doc) with three headings and paste the text under each. This makes copy/paste clean and prevents losing work if the portal times out.
Use this master structure for each item you submit:
- Section + line numbers
- Comments about Statutory Language
- Comments about the Rationale
- General
We recommend one “bundle” per section, like this:
Bundle A
B.9.b.(8) — Lines 202–208
- Statutory Language: …
- Rationale: …
- General: …
Bundle B
D.2.b — Lines 508–513
- Statutory Language: …
- Rationale: …
- General: …
Bundle C
C.1 — Lines 220–222
- Statutory Language: …
- Rationale: …
- General: …
In the APA portal, submit comments section-by-section - add a NEW comment for each section
The portal is organized by sections with three text boxes
If you see prompts like:
- Comments about Statutory Language*
- Comments about the Rationale
- General
…then you will submit each “bundle” by pasting the correct paragraph into the matching box.
3) Exactly what to paste where (by section)
A) Section B.9.b.(8) — Scope Exclusions (Lines 202–208)
Portal field: “Comments about Statutory Language”*
Paste the paragraph:
“NCAPP is concerned that the categorical exclusions…”
Portal field: “Comments about the Rationale”
Paste the paragraph:
“The rationale for these exclusions does not appear…”
Portal field: “General”
Paste the paragraph:
“From a workforce perspective…”
Tip: Add a first line in the Statutory Language box:
Re: Section B.9.b.(8) (Lines 202–208)
That helps reviewers immediately locate your target language.
Repeat for each NEW comment
How to handle citations in the portal (so they don’t get messy)
Include 1–3 brief citations only where necessary, typically in the Rationale or General boxes.
Use a simple format like:
- (Fouad et al., 2009; Kaslow et al., 2009)
- (HRSA workforce projections, 2023)
5) Quality checks before clicking submit
Before you hit Submit for each section:
- Check the first line includes the section + line numbers
(This is the #1 thing that makes reviewers take comments seriously.) - Make sure the Statutory Language comment references the text
(degree-based exclusions / supervision ratios / board ratio) - Make sure your Rationale comment makes the “not science-based” point
and asks for evidence or a competency-based alternative - Make sure your General comment connects to access-to-care/workforce
(community settings, rural, group homes, older adults, TBI/ABI)
6) Recommended submission strategy
Submit three separate comment entries (one per section), rather than combining everything into one long comment—this makes it easier for APA reviewers to route and respond.