; Top 10 Electronic Rule Filing Tips
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Top 10 Electronic Rule Filing Tips (Revised)

The Electronic Rule Filing (ERF) team has put together a list of Top 10 Tips for ERF users. It offers advice dealing with common questions and problems posed to the ERF Help Desk and raised during training. A detailed explanation of each tip follows the list. We encourage you to refer to it often when working on rule filings.

(1)    The ERF Website times out after 30 minutes.
(2)    The "Promulgated Under" statute cannot be changed once a package is created.
(3)    The recommended maximum package size is 25 rules.
(4)    Know how you want to answer online questions before you log into the ERF Website.
(5)    Never withdraw a rule unless you are 100% sure that is what you want to do.
(6)    If the Rule/RSFA Authoring System (RAS) software crashes often, check anti-virus software and available memory.
(7)    Allow LSC at least 30 days to prepare your rules.
(8)    Before filing, carefully review how the website displays your documents.
(9)    Typos, dates, and other data cannot be corrected in final filing.
(10)  Take advantage of training, the ERF Help Desk, the rule-filing kiosk, and JCARR for assistance.

(1) THE ERF WEBSITE TIMES OUT AFTER 30 MINUTES. If you do not click "Save" or "OK" or move to a new screen for 30 minutes, the site will time out and you will lose data entered since the last save. Be especially mindful of this time constraint when working on RSFA Forms 2 and 3, where long answers are sometimes entered.

(2) THE "PROMULGATED UNDER" STATUTE CANNOT BE CHANGED ONCE A PACKAGE IS CREATED. Pay attention when selecting your "Promulgated Under" statute when creating each package. Once you move past the package creation screen, the Promulgated Under statute cannot be changed. If you assign rule numbers, answer questions, upload documents, etc., and then discover that you selected the wrong statute when you created the package, you will have to start over. If you don't know whether the Promulgated Under statute is 111.15, 119.03, or something else, do not create the package until you find out.

(3) THE RECOMMENDED MAXIMUM PACKAGE SIZE IS 25 RULES. While the ERF Website does not prevent you from including more than 25 rules in a package, please bear in mind that, for a number of technical reasons, smaller packages are better.

(4) KNOW HOW YOU WANT TO ANSWER ONLINE QUESTIONS BEFORE YOU LOG INTO THE ERF WEBSITE. Prepare in advance to answer Forms 1 through 4. You can't bypass Form 1 to get to the document upload screen. If you put temporary answers ("filler") into a form, don't forget to modify the form and supply correct answers; otherwise, you may find yourself doing a revision or a re-filing. You may copy and paste text into online forms from a word processing document, email, or other electronic document. For example, if you have a word processing document with a list of 50 prior effective dates, you can open that document, copy the dates, and paste them into the prior effective dates field in the online questions.

(5) NEVER WITHDRAW A RULE UNLESS YOU ARE 100% SURE THAT IS WHAT YOU WANT TO DO. Withdrawals are irreversible. If someone tells you to withdraw a rule, triple-check to make sure that is really what they want to do. Do not withdraw to make corrections to a rule; that is done through a revision or refile. Withdrawing a final filing returns the rule to its status prior to the final filing. For example, if a rule was original filed, revise filed, final filed, and then withdrawn final, the rule is returned to its revised filing status. A withdraw final must be followed by a withdraw proposed in order for a rule to be removed from the JCARR process. After a withdraw proposed action, a rule filing ceases to exist. The only way to revive a filing after a withdraw proposed is to start over by creating a new package. If you have any questions or are at all unsure about withdrawing a rule, please contact the ERF Help Desk at 614-387-2078.

(6) IF THE RULE/RSFA AUTHORING SYSTEM (RAS) SOFTWARE CRASHES OFTEN, CHECK ANTI-VIRUS SOFTWARE AND AVAILABLE MEMORY. The number-one cause of RAS crashes is anti-virus software. Set virus-scan security level to low or intermittent. Another common cause is insufficient memory, especially when cutting and pasting from a word processing document into a RAS document. The current requirements for RAS: RAM: minimum 64MB, recommended 128MB or more; Free hard drive space: minimum 30MB; recommended 50MB.

(7) ALLOW LSC AT LEAST 30 DAYS TO PREPARE YOUR RULES. Please plan your requests based on the date you need the rules for drafting, not on the anticipated filing date. For example, if you need to file rules on August 1, and you need to download them on July 1 to begin drafting, you should request them through the Rule Filing Schedule & Downloading Prepared Rules website no later than June 1. Also, if you have previously requested the rule, the request can be modified by:

  1. At the Rule Filing Schedule & Downloading Prepared Rules website, select the "Change rule filing schedule" link.
  2. Enter the agency and division number (if applicable) of the rule. Click on "Submit".
  3. Click on "Edit" for the request you wish to modify.
  4. On the "Submit Rule Filing Schedule" page, enter the new file date and date needed and click "Submit."

Your new request will be sent to LSC for preparation.

NOTE: If the rule has been final filed in the last 60 days, please call the ERF Help Desk after entering the request to alert them the rule is being re-requested.

(8) BEFORE FILING, CAREFULLY REVIEW HOW THE WEBSITE DISPLAYS YOUR DOCUMENTS. Always print or view all documents from your workspace on the ERF Website, and examine them with great care, BEFORE pushing the red "File" button. System errors manifest themselves before filing. If the system experiences an error in recording an uploaded document, it will cause a flawed version to display, and that flawed version is what will be filed. System errors can be caught, and the ERF team can help correct them, before filing if you take care to examine how your documents display on the website. What you, the filer, see from the website before filing is exactly what LSC, JCARR, and the Secretary of State will receive after filing. If you fail to catch a system error prior to filing, it generally must be corrected through a formal revision or re-filing.

(9) TYPOS, DATES, AND OTHER DATA CANNOT BE CORRECTED IN FINAL FILING. A security feature of the ERF Website prevents filers from revising documents and data at the time of final filing. In typical packages, a rule is final-filed exactly as it appears in the latest-filed proposed version. If the latest-filed proposed version contains errors, the errors will carry over to the final filing. An agency discovering minor errors shortly before final filing therefore must decide whether to let the errors stand or to postpone the final filing and make a re-filed filing to correct them. Be careful to discover errors prior to original filing, but also take advantage of the first 35 days following original filing to re-proof your documents for errors. Revisions during the first 35 days do not prolong JCARR jurisdiction.

(10) TAKE ADVANTAGE OF TRAINING, THE ERF HELP DESK, THE RULE-FILING KIOSK, AND JCARR FOR ASSISTANCE. Electronic rule filing is a complicated and still evolving process. Feel free to attend the RAS, advanced RAS, and ERF classes more than once. Classes are updated continually to incorporate new filing procedures (such as SB 265) and improvements in the website. The schedule of classes is posted on the Rule Filers' Website, at http://filers.registerofohio.state.oh.us/jsp/trainingMaterial.jsp. Contact the ERF Help Desk (614-387-2078 or erfhelpdesk@lsc.ohio.gov) to schedule classes. On Mondays, from 8:30 am to 5:00 pm, or other days by appointment, you can get individualized assistance with actual filings at LSC's electronic rule-filing kiosk on the 8th floor of the Riffe Center. To sign up to use the kiosk, call the ERF Help Desk. And always feel free to call JCARR (614-466-4086) before or after filing with questions about JCARR procedures, timing your filings and public hearings, or answering questions on Forms 1 through 4.

 


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