Comment Intelligence

Most of what is written about a Medicare payment rule is one of two things: a summary that says nothing about who cares about it, or a skim of the ten comment letters everyone already knew about. I'll read the rule and the entire comment record in full — every filer, every argument, with verbatim quotes and the page each came from.

Regulatory and Public Comment Intelligence

Rule summaries

You don't need to wait for the detailed summary from your consultants anymore. We pull the need-to-know intel from the rule the week it publishes and rely on your regulatory team for the expertise you need (or reach out to us to see how we can help). What you'll get: what the agency proposed (or finalized), read in full and organized with pagination so you can focus on what matters most.

Comment intelligence

Have you ever tried to review the comment docket to see what others are saying about your issues? Comments can be in the tens of thousands but failing to read them leaves vital intel on the table. We will code every comment letter for you, argument by argument against a frame built from the rule's own proposals and requests for comment. We can even use your own comments and positions to create a point-by-point analysis of the record, customized to meet your needs.

How it works

Rules are read end to end, not searched for keywords. Issue-specific coding is completed argument by argument, against a frame built from the regulation's own proposals and requests for comment. Form-letter campaigns are identified and collapsed. Every source document, quote, and page number is verified.

If you don't see a product reflecting your needs, let's build it together.

What we read

  • Hospital Outpatient Prospective Payment System
  • Hospital Inpatient Prospective Payment System
  • Physician Fee Schedule
  • Ad hoc rulemakingEverything outside the three payment rules: national coverage determinations, requests for information, model rules. Contact for scoped pricing.

Rule summaries

The Rule SummaryFREE

The whole regulation, read end to end and summarized section by section.

The Stakeholder Summary**$4,500

What it means for you and your peers. The same rule read for one kind of organization: what this rule changes for hospitals, device manufacturers, trade associations or societies.

The Business Summary**$9,000

The rule read against your own codes, issues, and policies or products. Provision by provision, what it does to your constituency. This level is for a company or association briefing its own leadership on the rule's direct impact rather than summarizing a regulation.

**Covers BOTH the proposed and final rulemaking. A single stage is available upon request.

Comment intelligence

The Stakeholder Read$5,000

What one kind of filer actually said. Every hospital comment, or every specialty society comment, coded and quoted. For anyone who needs to know where their own sector landed, or where another one did.

The Issue Read$5,000

What everyone said about one provision. Every filer who addressed it, what they argued, and the page it came from. For a team with a single fight and no time for the rest of the record.

The Docket Read$15,000

The entire record, coded argument by argument, delivered as a workbook you can filter by filer, filer type, topic, position and argument. Form-letter campaigns are even collapsed to a single coded template with a signatory count, so volume never passes for consensus.

The Position Read$24,000

The Docket Read, plus your own letter coded against the record: who agreed with you, who took the opposite position, and who raised an argument you did not. Then, when the final rule publishes, a scorecard — what the agency adopted, and whose language it tracked.

The Stakeholder Read and Issue Read are flat at any docket size. The Docket Read and Position Read are priced for a record of up to 5,000 comments; larger records are quoted. Final rules with comments priced separately.

Packages

The Cycle$33,000

One rule, from proposal to final decision. A Business Summary and Position Read for a single rule.

The Year$90,000

All three payment rules, each one a full Cycle.

Consultant licences

The same work, licensed for unlimited use across your whole client book, under your own name, with no per-client fee.

The recordCoded against the rule's own topics. You build the client deliverables. The record and three positionsThree of your clients' letters coded against it, each with a scorecard.
One rule$55,000$75,000
All three rules$132,000$180,000

Additional positions prorated. Non-exclusive — quote it, cite it, build your own client work on it. The underlying coded dataset is licensed for your own client work and is not for redistribution or resale.

Start with a rule and a question

Tell us which issues you care about. Let us find the solution for you.

Courtney Savage, MPP
Savage Health Policy, LLC
csavage@shpconsulting.llc

Regulatory and Public Comment Intelligence

You don’t need to wait for the detailed summary from your consultants anymore. We pull the need-to-know intel from the rule the week it publishes and rely on your regulatory team for the expertise you need (or reach out to us to see how we can help). What you’ll get: what the agency proposed (or finalized), read in full and organized with pagination so you can focus on what matters most.

Have you ever tried to review the comment docket to see what others are saying about your issues? Comments can be in the tens of thousands but failing to read them leaves vital intel on the table. We will code every comment letter for you, argument by argument against a frame built from the rule’s own proposals and requests for comment. We can even use your own comments and positions to create a point-by-point analysis of the record, customized to meet your needs.

Rules are read end to end, not searched for keywords. Issue-specific coding is completed argument by argument, against a frame built from the regulation’s own proposals and requests for comment. Form-letter campaigns are identified and collapsed. Every source document, quote, and page number is verified. The machine does the first pass. A person who has written these letters decides what the record means.

If you don’t see a product reflecting your needs, let’s build it together.

I have spent more than two decades in federal health policy. For more than a decade I led a national surgical society’s regulatory comments: on the physician fee schedule and the hospital payment rules, on Medicare coverage determinations, and on proposals from FDA, FTC, and the organ transplant network. In that time I rarely saw a society read what everyone else had filed. There was never time, and so the intelligence in the record went unused. I have spent years reviewing comment records for clients across multiple rules and coverage determinations, and more than a year building the method on this page with them. This year it read a physician fee schedule record of more than 40,000 comments.

This is not a keyword search. It is an AI reader that works from two things I supply: a taxonomy built for each rule from the rule’s own proposals and requests for comment, and my own rulings on how a comment letter should be read, refined over every record I have coded. The taxonomy is fully transparent. Every topic points to the provision of the rule it came from, and every coded position carries the sentence it rests on and the page that sentence came from, so you can see how each answer was reached. Before anything is reported, I read a sample of the letters myself and compare my reading to the software’s. Where they disagree, the instructions are corrected and the record is read again until they agree.

— Courtney Yohe Savage, MPP

Any federal rulemaking or coverage decision that takes public comment. Our most recent work is on the Medicare payment rules and national coverage determinations:

  • Hospital Outpatient Prospective Payment System
  • Hospital Inpatient Prospective Payment System
  • Physician Fee Schedule
  • National coverage determinations
  • Ad hoc rulemaking — requests for information, model rules, and everything outside the payment rules. Contact for scoped pricing.

The Rule Summary

The whole regulation, read end to end and summarized section by section.

Free

The Stakeholder Summary**

What it means for you and your peers. The same rule read for one kind of organization: what this rule changes for hospitals, device manufacturers, trade associations or societies.

Scoped Pricing

The Business Summary**

The rule read against your own codes, issues, and policies or products. Provision by provision, what it does to your constituency. This level is for a company or association briefing its own leadership on the rule's direct impact rather than summarizing a regulation.

Scoped Pricing
**Covers BOTH the proposed and final rulemaking. A single stage is available upon request.

The Stakeholder Read

What one kind of filer actually said. Every hospital comment, or every specialty society comment, coded and quoted. For anyone who needs to know where their own sector landed, or where another one did.

$5,000

The Issue Read

What everyone said about one provision. Every filer who addressed it, what they argued, and the page it came from. For a team with a single fight and no time for the rest of the record.

$5,000

The Docket Read

The entire record, coded argument by argument, delivered as a workbook you can filter by filer, filer type, topic, position and argument. Form-letter campaigns are even collapsed to a single coded template with a signatory count, so volume never passes for consensus.

Scoped Pricing

The Position Read

The Docket Read, plus your own letter coded against the record: who agreed with you, who took the opposite position, and who raised an argument you did not. Then, when the final rule publishes, a scorecard — what the agency adopted, and whose language it tracked.

Scoped Pricing
The Stakeholder Read and Issue Read are flat at any docket size. The Docket Read and Position Read are priced to the size of the record and the scope of your positions. Final rules with comments are priced separately.

The Cycle

One rule, from proposal to final decision. A Business Summary and Position Read for a single rule.

The Year

All three payment rules, each one a full Cycle.

The same work, licensed for unlimited use across your whole client book, under your own name, with no per-client fee. Licensed by rule, for the coded record alone or with your clients’ positions coded against it. Non-exclusive — quote it, cite it, build your own client work on it. The underlying coded dataset is licensed for your own client work and is not for redistribution or resale. Contact for licence terms.

Savage Health Policy works with 501(c)(3) organizations on pricing.

Most engagements start with a read of the record and do not end there. Once you know what the rule does to you and what everyone else said about it, the next questions are the ones a regulatory consultant answers: what should we say, to whom, and by when.

Savage Health Policy provides that support directly. A read of a new proposed rule for your organization within days of publication. A comment letter in your own voice, grounded in what the record already shows. A scorecard when the final rule publishes, so next year’s letter starts from what the agency adopted. Standing regulatory counsel for organizations without a regulatory team of their own. The read tells you where you stand. The counsel tells you what to do about it.

Tell us which issues you care about. Let us find the solution for you.

Courtney Savage, MPP
Savage Health Policy, LLC
csavage@shpconsulting.llc

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Savage Health Policy
csavage@shpconsulting.llc
(276) 221-8300

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