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. I do both properly: what the rule says that is meaningful to you, and what the whole record said back.
The rule
What the agency proposed, read in full and organized so you can see what changes for you. Available the week it publishes.
Rule summaries
| Package | What you get | Price |
| The Rule Summary | The whole rule, read and organized | Free |
| The Industry Summary | The same rule, read for one sector | $2,500 |
| The Business Summary | Your codes, sites of service and products | $5,000 |
Applies to outpatient, inpatient and physician fee schedule rules, plus one-off rulemakings, coverage determinations and requests for information. Proposed and final rules priced the same. Discounts available for multi-rule needs.
The record
Every comment coded argument by argument against a frame built from the rule’s own proposals and requests for comment. Because every comment is measured against every topic in the regulation, a question the agency asked and almost nobody answered becomes visible instead of invisible.
Comment analysis
| Package | What you get | Price |
| The Segment Read | One policy issue, in depth, with page cites | $2,500 |
| The Add-On Segment | Another issue on a docket already built | $1,500 |
| The Docket Read | The whole record, as a workbook you can filter | $10,000 |
| The Position Read | Your own letter coded against the record | $15,000 |
| The Scorecard | What the agency adopted, and whose language it tracked | $6,000 |
Payment Rule Package
| Package | What you get | Price |
| The Year | All three rules, proposal to final, with a Position Read | $27,000 |
Bought separately, The Year is $30,000.
Consultant packages for your client book
The same work, licensed for unlimited use across your whole client book, under your own name, with no per-client fee. You build the deliverables.
| Coverage | What it includes | Price |
| One rule | Any one of the three | From $55,000 |
| Every rule | All three, plus one ad hoc rulemaking (additional available) | From $100,000 |
Non-exclusive. Quote it, cite it, build your own client work on it.
How it works
Rules are read end to end, not searched for keywords. Form-letter campaigns are identified. Coding is argument by argument. Quotes and page numbers are verified.
Start with a rule and a question
Tell me which rules you care about and what you are trying to find out. If the record cannot answer it, I will tell you that.
Courtney Savage
Savage Health Policy, LLC
csavage@shpconsulting.llc