RE: Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of
“Reasonable and Necessary” (CMS-3372-P)
Dear Administrator Verma:
On behalf of more than 100,000 specialty physicians, the undersigned members of the Alliance of Specialty
Medicine (the “Alliance”) write in response to proposals outlined in the aforementioned proposed rule. The
Alliance is dedicated to the development of sound federal health care policy that fosters patient access to the
highest quality specialty care. To facilitate your review of our comments, below is a list of key recommended
actions:
- Finalize an expanded MCIT pathway that also includes innovative diagnostics, drugs, and biologics, in
addition to FDA-designated breakthrough devices, allows for off-label use of products covered under
MCIT, and provides coverage for up to 5 years;
Read full letter here
