This year, Medicare's annual summer policymaking for hospital outpatient and physician fee schedule was released on July 29, several weeks later than normal, and pushing the 60-day comment window to September 27. That makes that CMS seems to have only a few short weeks in October to finalize rulemaking for its normal publication on November 1 - 60 days before January 1.
The late calendar hasn't impeded comments, at least not for the PFS rule. Last year, the PFS rule had 15,368 comments. The day before the rule closed, there were already nearly double that, at 29,826 comments. AT THE CLOSE OF COMMENT PERIOD, PFS HAD RECEIVED 42,435 COMMENTS THIS YEAR.
Last summer, the OPPS rule got 3,540 total comments. In contrast, this year, and with one day to go, the OPPS rule for CY2020 has received just 1,678 comments. AT THE CLOSE OF COMMENT PERIODS, OPPS HAD RECEIVED 3,907 THIS YEAR.