cross-read section II.E (care-management reconsideration) of CMS-1848-P; extract pincites for RFI part (d) #649
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Reference: homelab/stack#649
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RFI part (d) explicitly ties to section II.E of the same rule, where CMS reconsiders the future of care management services. Close-read II.E in data/fr_downloads/2026-14327.txt, extract what is actually proposed vs merely discussed, and build the pincite list (page + paragraph refs resolvable via stack bib fr-jump) so P44 answers to part (d) align with — and cite — the rule's own proposals rather than restating them from memory.
Close read done (2026-08-20). Full pincite analysis:
docs/spec/2026-08-20-cy2027-iie-crossread-palliative-rfi.md; condensed as notebook Section 6 with live fr-jump links. Headline findings: (1) nothing in II.E is proposed — the only operative care-management-adjacent text is II.D's G2211 changes (cross-referenced 91 FR 43937 ¶3), so part (d) must answer II.E's questions, not endorse proposals; (2) three CMS concessions anchor the response — limited care-management uptake (91 FR 43938 ¶5), APCM's FFS residue (43941 ¶11), ACO infrastructure driving adoption (43942 ¶1); (3) the part-(d) question cluster is 91 FR 43938-43939 (two-track, consolidation, supervision, initiating triggers, plus the open data invitation at 43939 ¶2); (4) vocabulary: II.E never says 'serious illness' — mirror 'chronic conditions'/'high-risk beneficiaries' when drafting.