Seema Verma
Administrator
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-4190-P
P.O. Box 8016
Baltimore, MD 21244-8016
Submitted online via regulations.gov
Medicare and Medicaid Programs; Contract Year 2021 and 2022 Policy and Technical Changes to the
Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program,
Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (CMS-4190-P)
Dear Administrator Verma:
On behalf of more than 100,000 specialty physicians from 14 specialty and subspecialty societies, and
dedicated to the development of sound federal health care policy that fosters patient access to the
highest quality specialty care, the undersigned members of the Alliance of Specialty Medicine (the
“Alliance”) write in response to proposals outlined in the aforementioned proposed rule.
Network Adequacy
We are deeply concerned with CMS’ proposals that would codify certain specialties for purposes of
network adequacy. The Alliance membership is comprised of a number of subspecialty physicians, many
of whom are not counted in current network adequacy metrics. We have repeatedly encouraged CMS to
require use of a more robust set of physician specialty types (i.e., the Healthcare Provider Taxonomy
Code Set) when calculating Medicare Advantage (MA) network adequacy, given many subspecialties
have faced challenges participating in MA networks. For example, Mohs surgeons were altogether
excluded from MA networks in some areas of the country. We ask CMS to reconsider its proposal to
codify a list of provider specialty types that would exclude any medical specialty or subspecialty.
Read full letter here
