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管理办法是确立具体的活动规则,提出处理问题的精确准则与程序规范,确定执行法律法规的方法措施的一系列规定,是与法律法规配套的实施细则,应具有很强可操作性。管理办法颁布以后,各法定管理机构应该能够在实践中加以实施。因此在制定这类管理办法时,可行性应该列为重点考虑的问题之一。卫生部制订了《卫生行政许可管理办法》(征求意见稿),广泛征求意见,这是使之完善的有力措施。我们根据多年的卫生监督实践,尤其是卫生许可证汇审、发证、管理工作中的实际问题,围绕卫生行政许可管理办法的可行性这个侧面做些探讨。
The management measures are the establishment of specific activity rules, the precise standards and procedural norms for handling problems, and the series of provisions for determining the methods and measures for the implementation of laws and regulations, which are the implementation rules that are in accordance with laws and regulations and should be highly operative. After the management measures are promulgated, all statutory regulatory agencies should be able to implement them in practice. Therefore, when formulating such management methods, feasibility should be listed as one of the key issues to be considered. The Ministry of Health has formulated the “Measures for the Administration of Health Administrative Licensing” (draft for soliciting opinions) and solicited opinions widely. This is a powerful measure to make it perfect. Based on many years of hygiene supervision practices, especially the practical issues in the review, issuance and management of health licenses, we have conducted some discussions on the feasibility of the health administrative license management measures.