Over the past year, we’ve seen a clear pattern across U.S. federal agencies: public comment periods are becoming harder to manage, and the recent government shutdown only added more pressure.
Even during a shutdown, rulemaking doesn’t fully pause. Agencies can keep drafting regulations, but reduced staffing slows everything down. Venable LLP notes that while comments continue to come in, there often aren’t enough people available to review, process, or publish them, creating major delays. This was visible at agencies like Centers for Medicare & Medicaid Services (CMS) , where limited staff directly slowed payment-rule work and related policy activity.
And this is on top of the pressure agencies already face. As the US Government Accountability Office (GAO) points out, federal rulemaking is inherently complex, involving analysis, internal review, and public feedback. Even with full staffing, keeping the process transparent and efficient can be a challenge.
Why Public Comment Periods Are Overwhelming Agencies
When a new rule or policy update is proposed, agencies typically open a 30–60 day window for public comments. In that time, they might receive anything from a few hundred to tens of thousands of submissions, from short notes to multi-thousand-page attachments. Regulations.gov confirms just how wide that range can be, and every substantive comment must be reviewed and addressed.‑thousand‑page attachments. Regulations.gov confirms just how wide that range can be, and every substantive comment must be reviewed and addressed.
But the strain goes deeper:
1. Manual review slows everything down
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2. Small teams, massive workloads
with full staffing, keeping the process transparent and efficient can be a challenge.
3. Delays impact policy timelines and compliance
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4. Shutdowns magnify existing problems
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How Agencies Are Solving This, and How We Help
To keep up with the workload, some agencies and legislative bodies are modernizing their processes. They’re adopting structured content systems, automated intake tools, and centralized document workflows to speed up review while staying compliant with the APA.
ACUS has also highlighted the need to improve how agencies collect, publish, and respond to comments, including preventing backlogs, ensuring timely public access, and simplifying response workflows.
At Propylon (part of RWS), we support agencies by helping them modernize key parts of this process:
- Automated comment intake using a single source of truth: bringing email, PDF, and web‑form submissions into one structured, searchable system.
- Categorization and theme analysis: Automatically grouping similar comments using AI, identifying duplicates, and surfacing emerging issues.
- Streamlined drafting and response workflows: Helping teams respond faster while maintaining quality and compliance.
- Audit-ready transparency‑ready transparency: Every classification, response, and decision is logged to support APA and regulatory requirements, even during staffing shortages.
Agencies that move to structured processes shorten timelines, reduce backlog risk, and dramatically cut manual workload without growing their teams.
Comment Volume Isn’t Shrinking, but the Workload Can
Public comments are essential for transparency and public trust, but managing them shouldn’t overwhelm agency teams. With the right workflows and tools, agencies can keep up with rising volumes, even during shutdowns or staffing challenges.
If your agency is dealing with mounting backlogs or limited capacity, we’d be happy to share how structured automation can help lighten the load.