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A new CMS rule (Link to rule CMS-1600) has ignited a firestorm of comments, first starting with physicians(⁵), then joined by their patients.          

By Friday 1/24/2014, over 12,000 comments were submitted electronically to the federal register website federalregister.gov and referenced by a downloadable summary index file.

Early Saturday morning (1/25), the critical index file was removed from the website, with the official comments count reduced to 2,296.  By eliminating the index file, analyzing the comments in an orderly fashion is impossible.

Where is the critical index file for  comments? 
Why were over 70%  of the comments (9,741) on CMS rule 1600 not counted on the frontpage?
Why are the comment counts going up and down?

Emails are sent, responses pending...

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Explanatory notes of timeline: 

1. 1/24/2014 3:19PM : federalregister.gov: The number of comments on rule 1600 frontpage was 12,023.  I downloaded the official summary index file of all comments.  File here  (CSV, View with excel)
   I  reviewed the summary index file & found less than 3,000 comments submitted robotically
2. 1/25/2014 - AM - I noticed drastic reduction in comment count to 2,296. (see table above).   I attempted to locate summary index file, but found that the link and file URL was removed..
    

Footnotes

1) At the same time of the comment count change on the Rule frontpage, a footnote was added to the regulation.gov webpage displaying the comment count:

*This count refers to the total comments received on this docket, as of 11:59 PM yesterday⁽⁴⁾, from Regulations.gov and alternate means. All comments including the bulk submissions received for this docket may not be posted at this time; therefore, the counts may differ between: total comments received and posted, as well as the counts shown on the Docket Folder Summary page

2) Although the footnote above remained on the website, the comment count resumed to indicate the total for the entire review period .

3) The Index file (type: CSV) was downloaded 1/24  through the official regulations.gov link  Link to downloaded Index file

4) It is highly unusual for regulations.gov website to insert a footnote with a relative timeframe (i.e. yesterday) and interpret it differently from day to day (i.e. in chart above, compare comment count of 1/25 and 1/27).

5) The Physician Registry Coalition visited the White House with a document specifying list of issues  or here

For more information: please email me   OR  visit our website's media catdoor

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Last modified: Tuesday November 10, 2020.