Resources & Education
Rule-Making Process
Understanding Proposed Rules before they become Final Regulations.
Understand the Final Rules before they become the law.
Before the Final Rule
Every Final Rule begins with a proposal.
The Proposed Rule is more than an announcement of likely policy. It explains the CMS’s current thinking, identifies the data and methodology being used, presents alternatives, and creates an opportunity for public comment.
Understanding the Proposed Rule before it becomes final gives organizations time to interpret implications, evaluate assumptions, participate thoughtfully, and prepare for more than compliance.
Proposed Rule
Policy, methodology, data, assumptions, and questions are published.
Interpretation
Stakeholders evaluate practical, clinical, financial, and operational implications.
Public comment
Evidence, analysis, concerns, and recommendations enter the formal record.
Final Rule
CMS responds, revises where appropriate, and establishes final policy.
A timeless framework
The year changes. The analytical questions remain.
A 2027 Proposed Rule may contain different facts than a future proposal, but organizations can use a consistent framework to examine each new rule.
What is being proposed, why is it being proposed, what assumptions support it, and what could it mean in practice?
Participation creates understanding
Different perspectives reveal different consequences.
Policy may be expressed through technical language, but its effects are experienced through patient care, clinical practice, staffing, operations, reimbursement, finance, technology, and organizational strategy.
Clinical perspective
Consider how definitions, assessments, care planning, and patient needs interact with the proposal.
Operational perspective
Evaluate workflow, staffing, systems, documentation, capacity, and implementation effects.
Financial perspective
Quantify payment, cost, cash-flow, margin, and sustainability implications.
Experience through change
From Cost-Based reimbursement to IPS, PPS, and PDGM.
John Reisinger has worked through multiple home health reimbursement systems changes as a Medicare auditor, provider executive, consultant, educator, and industry participant.
That history supports an approach that looks beyond isolated provisions to the behavior, incentives, interactions, and future consequences a rule may create.
Read
Understand the proposal and supporting analysis.
Model
Evaluate impacts and alternatives.
Respond
Educate, comment, and prepare.
Education through participation
Support for the process.
IFS4hh can assist organizations and industry groups in moving from the published proposal to an informed understanding and a constructive response.
- Proposed Rule analysis and interpretation
- Executive, board, and team education
- Financial and operational impact modeling
- Scenario and sensitivity analysis
- Development and review of formal comments
- Presentations, webinars, and facilitated discussions
- Preparation for Final Rule implementation
Beyond compliance
Use the rulemaking process to understand, participate, and prepare.
The strongest time to begin interpreting a policy is while it is still being proposed.