draft the comment: per-question responses to RFI parts (a)-(e) with pincites and evidence #650
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Draft the public comment for docket CMS-2026-2377 answering the community-based palliative care RFI (91 FR 43949–43950) question by question:
Every claim cites the P42 Zotero evidence base or a P43 notebook exhibit. Review pass: walk the RFI text and confirm each solicited question is answered or explicitly declined. Keep the ESRD/hospice-specific material out — CMS directs those comments to their own dockets (per the RFI background).
Draft ready for review: docs/comments/2026-09-cms-2026-2377-palliative-rfi-draft.md (
6897c18, merged to main). Body ~7,200 words of which ~830 are CMS's quoted questions and the verbatim PCM-1/2/3 descriptors; 113 sources in Appendix A (per part: a 11, b 19, c 23, d 29, e 23, plus 5 standards and CMS's 3 own citations), every body PMID cross-checked against the appendix; Appendix B carries the PRISMA counts and protocol pointer; a Coverage check table maps every paragraph ¶938–962 to the section that answers it. Two questions are partially declined on the record: ¶946 (no included study compares life-expectancy intervals head to head, so no State Medicaid interval is endorsed as evidence-based — the draft still answers 12 months over 6) and ¶961 (no study evaluates MVP-level reporting for a palliative population, so no MVP composition with weights/benchmarks is specified).Review these first, in order of exposure: (1) part (a) as a whole — all 11 studies are hospice-benefit studies; the churn/margin/ownership recommendations are argued by analogy and the section says so; (2) the electronic-care-plan element in part (d) rests on one 48-patient pilot (Voruganti 2017) and one unretrieved record (Fathi 2016), yet PCM-2 makes it mandatory; (3) the CBE 3665 'not sufficient' position turns on one non-US validation (Takahashi 2025, ICC 0.54) — the measure's three US foundational sources were unretrievable at full text, so the negative case is partly an evidentiary-gap argument. Also: the conversion-factor figures came from pfs.rules, not the lake, and no per-code dollar figures appear. Signature block has [Name]/[Organization]/[Title] placeholders. Leaving this open for your edit; #651 (submission) follows.
Full-text pass for the sources the body relies on (2026-09-11). Of 107 cited PMIDs, 79 already had PDFs in Zotero. For the 28 without, plus CMS's two other serious-illness citations: the lynchpins are now on file — the Innovation Center white paper Palliative Care Projects: Synthesis of Evaluation Results 2012–2021 (17 pp., cms.gov PDF) attached to P4G7SWZN, and the CAPC Building and Supporting Effective Palliative Care Teams toolkit captured as an 11-page PDF (headless print, dated footer) on T9E2E9BK. Four more came from Semantic Scholar open-access copies (PMIDs 21958012, 22500481, 24921162, 27533892). Routes tried for the rest: Unpaywall best location AND every listed oa_location, PMC open-data S3 bucket (OA subset only — author manuscripts are not in it), PMC web (bot check, 203), Europe PMC (EBI unreachable from the rack; render backend 520), publisher PDF links via a real headless browser (Wiley 403). Not used: the VPN fallback mirror tier. Spelling: 45 British forms in the body Americanized (
bdba810); appendix titles left verbatim.26 still without full text — paywalled or behind NCBI's browser challenge; your library access or a minute each in a browser for the seven PMC author manuscripts:
Second full-text pass via the corwins.media direct tier (libgen.li through the gluetun proxy), per the user's direction: 22 of the 24 remaining DOI-bearing sources fetched and attached to their Zotero items as 'Full Text PDF' (including both Kelley 2017 and the Dolin/Teno/Prsic/Sengupta hospice-integrity papers, the CAPC consensus papers PMIDs 19922199/21133809, and the CBE 3665 source Gramling 2016 PMID 26596879 and Ingersoll 2018 PMID 29729348). Route: index.php?req= with the article object type → edition.php → md5 → ads.php?md5= (the edition page's link carries &downloadname=, which makes ads.php return an empty 200; the bare form returns the keyed get.php link) → get.php, 1 s / 3 s pacing. Still without full text: 29125784 (Kelley & Bollens-Lund 2018, CMS footnote 114 — libgen has it, md5 known, but get.php answered 500/502 across two mirrors and three retries: throttled; retry later), 33933617 (not on libgen; PMC8419009 author manuscript), 11009798 (no DOI, 2000 hospice compliance plan) and 35837526 (no DOI; PMC9242575). Zotero container restarted and healthy after the attach.
Third pass (2026-09-11): PMID 33933617 — PMC's efetch (db=pmc) returns the full author-manuscript JATS for PMC8419009 (19 body paragraphs, 31 references) even though the PDF is behind the bot check; rendered to an 11-page PDF (title/authors/abstract/body/references, marked as a JATS rendering, figures and tables omitted) and attached. PMID 35837526 (Rand Health Q 2022) has no DOI and no PDF of the Health Quarterly summary, but RAND serves the full report it abstracts, RRA400-1 'MACRA Palliative Care Quality Measure Development—Testing Summary Report: Feeling Heard and Understood', as a PDF — attached with that note. Europe PMC's render backend answers 520 for every PMCID (also through the VPN exit), and efetch returns front matter only for PMC5756466 and PMC9242575. Full text is now on file for 105 of the 107 studies cited. Still missing: 29125784 (Kelley & Bollens-Lund 2018; on libgen, md5 596979013aaf94469ab5ece28a41d3b7's sibling edition, get.php throttled 500/502 on every retry today — rerun lg_articles.py later) and 11009798 (Caring magazine, May 2000, NAHC trade journal: no DOI, not in PMC, not on libgen — probably only in NAHC's print archive).
Kelley & Bollens-Lund 2018 (PMID 29125784) obtained: OpenAlex/Unpaywall record the published version as CC-BY (hybrid OA); the publisher copy now redirects to journals.sagepub.com behind Cloudflare (403 to every client), but the PMC deposit (PMC5756466) downloads once PMC's interstitial has completed in a headless Chromium session — the article page loads on the second request after a 6 s wait and the PDF link on the page then delivers via a navigation download (a plain request to the same URL is 403). Attached as 'Full Text PDF (CC-BY, PMC5756466)'. Full text is now on file for 106 of the 107 cited studies; the one exception, PMID 11009798 (Caring magazine, May 2000), is carried as citation-by-abstract per the author's decision.