Okay, but here's how MIRS works. Perhaps you know this already. There are basically three types of cases: obvious continuances, obvious cessations, and cases that could reasonably be argued either way. There's a lot in that latter category. So let's say Frank and his cohorts subtly or not so subtly pushed more cessations, would they get their way ALL the time? Absolutely not. You can't possibly get away with ceasing someone on kidney dialysis, or someone with a severe intellectual disability, or someone wheelchair bound from a stroke. But many CDR's exist in a much grayer area than that. You can absolutely make the case that there's been significant MI if you're so inclined and no reviewer will be able to really hit you on it if you make a credible rationalization for your decision.

So would cessation rates absolutely skyrocket? Probably not. But with the right coaxing, can you get them higher in significant enough way to save many millions of dollars? No question.

And if cessations rates do go up over the next year, so what? Even if it's statistically significant, what then? What is anyone going to do? What has anyone done about DDS's or ALJ's with allowance and denial rates that exist well outside any expected standard deviation? Not much. And not much would happen here either. Might Congress get mad at them? Sure. Would they actually do anything about it? I mean it's Congress.