Last week, news broke that the long-simmering story about insider information leaks had reached public filing of an SEC legal document (news links here, SEC document online here.)
One interesting aspect is to actually read the SEC 51-page filing. Business journalists picked up on the lurid details - how one individual was allegedly dangling future benefits in front of a CMS employee, and embarrassing turns of speech clipped out of emails from 2013 and 2014.
But policy watchers can also read the SEC document for some interesting insights into how the wheels turn at CMS. For example, in January, I was describing to a client how, if you want to affect June 30 annual rulemaking, you need to back up to publications or communications in January, February and March, because issues at the agency will converge towards final meetings and decisions in April if possible for writing, editing, and troubleshooting sessions in May and final vetting underway by early June.
The SEC documents contain stories that mirror that timeline - for example, there are emails traded about policy meetings in March and April, and the crafting of CMS debriefing and decision decks on that timeline, all in preparation for rulemaking that must be released around June 30 after vetting by higher levels at CMS and legal counsel and the Office of Management and Budget.
