If you submitted a comment, you know what your organization had to say. But do you know who agreed with you? Who argued the other side? What evidence did they bring? Which of your own members said something you did not? Most people don’t. This year more than 40,000 comments were submitted on the physician fee schedule, and almost none of them will be read by the people they matter to most.
I understand the struggle, because for more than a decade, I was just like you. For several years, I worked with clients on coverage determinations, ad hoc policies, and the major payment rules. When I wrote a surgical society’s comment letters to CMS, FDA, and other agencies, I read the rule, wrote the letter, filed it on the deadline, and moved on. I rarely read what anyone else had filed. There was simply never time.
Because of this lack of time, we miss out on some of the most important commentary all over the health policy landscape. Most of the time, it all goes unread because it is built to be unreadable. Half the arguments are in attachments, or a quarter of a docket can be one form letter. Sometimes, comments are even filed under obscure or missing organizational names. 1,280 comments on this year’s hospital outpatient rule listed no organizations at all, and one of them was MedPAC.
In an effort to make all regulatory professionals’ lives easier, I built a way to read the whole rule and the whole record: SHP Comment Intelligence. Together, you and I build the taxonomy together: we define what the rule proposes, the questions it raises, and which of those things matter to you. Then, the software makes the first pass. Every letter and every attachment is coded against that taxonomy, with each position cited alongside a direct quote and page
The most important step comes next: I check the tool, validating against the original record and correcting any discrepancies alongside copious rereads A summary can often miss what’s not in the record or mistake “support with modification” for opposition. Al may not get the nuance of a long-disputed policy. That takes someone who has written those letters, which is why I’m here.
Whether you are a society that wants to know where its members and peers landed, a company with one provision at stake who wants the landscape, a regulatory consultant with a client book who needs the record read once and used many times, or even an organization with no regulatory staff looking for help on a critical issue, The SPH Common Intelligence Tool is here for you.
If you’d like to see the full landscape without spending weeks reading and assembling it, work with me! Send me the rule and the issues you care about, and I will tell you what the record holds on it. Options include rule summaries, single issue reads, and reads of everyone in your sector, all completed in days!
Learn more here, or email me any questions at csavage@shpconsulting.llc.