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- Primary Program Rule Objectives:
- Implement program consistent with congressional intent
- Resolve ambiguities necessary to facilitate Program Execution
- Protect the Consumer
- Ensure Program Success
- NTIA should avoid codifying rules governing all aspects of the program
- Achieve an effective balance between establishing a program framework
and necessary requirements, without unnecessarily curtailing discretion
in program implementation
- Allow the Program Administrator to adopt best practices and effective
cost tradeoffs for the program, in consultation with NTIA as
appropriate
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- As a general guideline, rules that drive how it will be done should be
avoided unless mandated by the Act (e.g. receive coupon via USPS)
- Examples
- Coupon Format (Paper vs. Plastic)
- Coupon Application Process and Methods
- Waste, Fraud and Abuse Methods and Techniques (Serial Numbers,
Watermarks)
- Retailer Certification
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