Put your comment where your money is: An analysis of public comments on annual proposed changes to Medicare reimbursement rates

This paper examines the annual Medicare acute care hospital inpatient prospective payment system (IPPS) rate update rules, which are consistent, comprehensive, and have a high impact on stakeholders. I collect a random sample of comments on IPPS rules for fiscal years 2005 to 2014, and generate a dataset with information about the types, locations, and expertise areas of authors and organizations submitting comments on these rules. I also examine the differences between payment rate values in proposed rules and corresponding values in final rules, and observe the relationships between these outcomes and the composition of public comments across a number of categorical aspects. Comments in the sample were predominately submitted by providers (both organizations and clinicians), which is unsurprising as these rules directly govern the payments made to these groups. Commenters usually had identifiable expertise in the areas of medicine, health, law, health administration, business administration, healthcare finance and accounting, public policy, or legislative affairs, and were largely concentrated in Washington, D.C., the Northeast, and the Midwest. There are some discernible correlations between the percentage of comments submitted by individuals with certain areas of expertise and changes made to payment rates (both in relation to final rates from previous years and proposed rates). A crude interpretation of these relationships purports that some subsets of commenters are particularly responsive to rate changes, and that in turn CMS is responsive to some of the positions advocated by other subsets of commenters.