Comment Letter

Neurosurgery Comments on Integrating Specialty Care in Population-Based Models

  • Quality Improvement and Patient Safety

Miranda Lynch-Smith
Deputy Assistance Secretary, Office of Human Services Policy (HSP)
Assistant Secretary for Planning and Evaluation, Room 415F
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
Submitted electronically via: PTAC@HHS.gov

RE: Improving Care Delivery and Integrating Specialty Care in Population-Based Models Request for Input (RFI)

Dear Ms. Lynch-Smith,

The Alliance of Specialty Medicine (the “Alliance”), representing more than 100,000 specialty physicians from sixteen specialty and subspecialty societies, is deeply committed to improving access to specialty medical care by advancing sound health policy. On behalf of the undersigned members, we write to provide feedback on the aforementioned request for input.

Background

Members of the Alliance have a long history of engaging the Physician-Focused Payment Model Technical Advisory Committee (PTAC) on the establishment of specialty-specific alternative payment models (APMs) that address recognized challenges in the delivery and cost of care for certain conditions and procedures. Unfortunately, none of the PTAC-recommended models from Alliance members have been approved by the Centers for Medicare and Medicaid Innovation (CMMI) as Advanced APMs for purposes of the Quality Payment Program (QPP).

Click here to read the full Neurosurgery Comments on Integrating Specialty Care in Population-Based Models.