CMS/CCIIO needs to synthesize a large number of public comments on its annual Affordable Care Act rulemaking.

Each year, the Centers for Medicare & Medicaid Services (CMS) publishes the Notice of Benefit and Payment Parameters (NBPP) or “Payment Notice,” an annual Affordable Care Act (ACA) rule that covers health insurance marketplace operations and standards for health plans, insurance brokers, and the risk adjustment program. The Administrative Procedures Act requires CMS rulemaking to consider all the relevant matter submitted by interested parties (5 USC § 553). The final rule must include a summary of all relevant comments and CMS’s response to those comments. Once the proposed rule is published, the public has 30 days to submit comments, which are then considered as CMS finalizes the rule. 

Given the number of stakeholders involved, the volume and complexity of the comments are considerable, and synthesizing them in an accurate and timely manner is a daunting task.

NORC supports the public comments period by compiling and analyzing the public’s feedback that results in policy briefs.

Because of the compressed schedule for reviewing and responding to comments on the proposed Payment Notice and the potential for an increased number of comments, NORC must quickly evaluate the proposals' potential policy implications and provide CCIIO with a comprehensive analysis of the public comments.

NORC assembled a team of policy experts with multiple years of experience engaging in ACA policy and used rapid qualitative data collection processes to facilitate a reliable and comprehensive response to the CCIIO rulemaking schedule.