Helping a Federal Agency Respond to an Essential Health Care Final Rule

Case Study - Findings Analysis and Insights - Policy Analysis, Implementation and Compliance - Program and Project Management - Technology Enablement - Veteran Health

Helping a Federal Agency Respond to an Essential Health Care Final Rule

Posted on 04.08.24

Finding support for standing up a resource room and creating regular performance reports

OWH needed support to create and staff a resource room that would coordinate requests and responses from and to the field, work with subject matter experts (SMEs) to coordinate the responses, host live chats, develop and update artifacts, and produce utilization analyses and reporting requirements identified by OWH. The Office also needed reporting support to demonstrate project performance and status. Examples of these reports include dashboards, weekly tracking of responses, status reports, summary reports and high-level executive communications documents.


OWH chose Aptive, a business management consulting company, to identify, validate and deploy a solution to aggregate, categorize and analyze comments received from the Interim Final Rule published in the Federal Register. Aptive has extensive experience working with VA, with project management and with policy and regulation analysis, implementation and compliance.

Implementing a New Tool

Aptive recognized the magnitude of reducing the level of effort for comment processing with only a matter of days before the regulation would be posted. To resolve this issue, Aptive’s research and development team developed a tool to interface with the website application programming interface. The tool ingested and analyzed public comments in real time. Applying this solution immediately resolved an issue common to manual processing methods by reducing instances of repeated comment data.

Program and Project Management

Aptive hired a project manager (PM) to serve as the main liaison to OWH. The PM was responsible for overseeing the entire project and ensuring all deliverables were accurate, on time and of high quality. We also hired a program analyst and management analyst to staff the Reproductive Rights Resource Room and monitor Federal Register comments, including collecting and analyzing data and interpreting results. The management analyst also provided analysis and advice for effectively managing the project.

After reviewing and analyzing inquiries, we delegated specific inquiries to the appropriate SMEs for their response. Inquiries we responded to addressed policy, education and training, procedure, ethics, workforce management and legal ramifications for clinical personnel. Comments gathered from the field informed any required development of policy and guidance, such as standard operating procedures, and could, in turn, impact development of future policy as well as a revision to a final ruling.

Training and Content Review

Aptive collaborated with multiple SMEs to review reproductive health training and content, ensuring timely completion and progression to the next step. We created a training and content review tracker to maintain version control of all reproductive health training and content and coordinated with VHA Institute for Learning, Education and Development partners for reproductive health training accreditation, recording and upload to the Training Management System. In addition, we drafted and prepared slides and agendas for meetings and briefings and prepared and maintained meeting notes.


Developing best-in-class tools to synthesize public policy

Aptive provided OWH with an organized catalog of deduplicated and well-formatted comments on a weekly basis. Our staff worked closely with OWH to tailor this output to their needs over the 32-day comment period, identifying topics, highlighting issues identified by OWH and condensing the tens of thousands of scripted comments while extracting unique information from them.

Using standards from a report on comment analysis tools conducted by the Federal Chief Data Officers Council, Aptive calculated a potential savings by OWH of about 4.5 hours per 100 comments by implementing its solution. The final count of distinct comments was nearly 60,000 received over 30 days, with 93% received in the last 10 days — which equates to saving roughly 2,700 hours of employee time.

Results at a Glance

  • Provided OWH with a weekly, organized catalog of deduplicated and well-formatted comments on a weekly basis
  • Condensed tens of thousands of scripted comments while extracting unique information
  • Potential savings to OWH of about 4.5 hours per 100 comments, or 2,700 hours of employee time