Case Studies

From multi-year task orders with a team of subcontractors to smaller-scale individual research efforts, L&M has led dozens of research projects from government agencies, as well as private clients.


Centers for Medicare & Medicaid Services (CMS), June 2019 through June 2021 (with an additional option year)

Objective

Provide support services and technical assistance to CMS’s Hospital and Ambulatory Policy Group (HAPG) and Medicare Plan Payment Group (MPPG) during the Medicare Physician Fee Schedule (PFS) and Part C/Part D rulemaking cycles. In particular, L&M provides support services by triaging, reviewing, and summarizing public comments received in response to Notices of Proposed Rulemaking (NPRMs). Further activities under the contract include managing CMS’s resource mailbox for processing, tracking, and responding to inquiries throughout the year, providing technical assistance in the review of the preamble and regulations text, and updating existing CMS publications and sub-regulatory guidance.

Challenges

Extremely tight deadlines for modifying and finalizing proposed policies coupled with a recent surge in the number of public comment submissions has made it increasingly difficult for CMS to manage, review, and respond to the important input provided through public comment. For instance, for the CY 2020 PFS Proposed Rule, CMS received over 40,000 public comments, with more than 18,000 submitted in the final 48 hours of the comment period. Managing this volume of comments in such a short timeframe gives CMS little time to carefully consider public input and make the regulatory and policy decisions needed to finalize and publish the final rule.

Approach

Leveraging its deep understanding of the Medicare program, including expertise related to Medicare Advantage, Part D, and the PFS, as well as our past experience reviewing public comments, the L&M team developed a customized web-based Triage Tool to manage the public comments received, facilitate comment review and triaging, store comment review information, and generate reports for CMS. For each of the three public comment periods L&M supported during the base year, the team worked with subject matter experts at CMS to adjust the review process and design report templates to meet the specific needs of each CMS policy team. L&M reviewed every comment received and provided CMS with descriptive information about the comment and submitting individual/organization, identified the topics addressed, and indicated whether the comment supported or opposed the policies in the proposed rule. This review information was packaged for CMS in customized reports and delivered to CMS throughout the comment period. Health services research Consumer testing Literature reviews and environmental scans


Results

Our Team:

  • Operationally optimized the process of reviewing public comments.
  • Helped CMS understand in real time which topics were of most interest to the public so that it could adjust and augment its regulatory and policy resources as needed.
  • For the PFS proposed rule, reviewed and triaged over 40,000 public comments, allowing CMS subject matter experts to focus their attention on comments related to their areas of expertise.
  • For the Part C/D Advance Notice comment period, reviewed approximately 900 public comments and delivered a 550-page comment report 72 hours after the close of the comment period to support CMS staff in responding to the public input.

CMS has exercised the first of the two option periods and tasked the team to develop and implement automation to further enhance operational efficiency.