RE: Medicare, Medicaid, and Children’s Health Insurance Programs; Program Integrity
Enhancements to the Provider Enrollment Process
Dear Administrator Verma:
On behalf of more than 100,000 specialty physicians from 15 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 the above-referenced final rule with comment period issued by the Centers for Medicare
and Medicaid Services (CMS).
The Alliance supports efforts that protect federal health care programs and the Medicare trust fund from
fraud, waste, and abuse by unscrupulous providers. While we understand that statutory requirements and
CMS’ rule to require disclosure of affiliations seek to achieve this goal, we are concerned that the rule does
not sufficiently balance concerns around administrative burden.
In the rule, CMS finalizes a “phased-in” approach to implementing new program integrity requirements for
disclosure of affiliations with disclosable events, rather than requiring disclosures by every newly enrolling
or revalidating provider or supplier. The Alliance thanks CMS for this final policy, which significantly
reduces burden for the majority of providers and suppliers who would otherwise be subject to the
disclosure requirements. At the same time, we are concerned that the finalized requirements are still
overly burdensome, and that providers and suppliers, including specialty physicians, would experience
significant difficulty in meeting disclosure requirements should they be required to report, contrary to CMS’
goals under the Patients over Paperwork initiative. This is true both under the current rules that require
dislosure upon request from CMS, as well as in future phases, where requirements would apply more
broadly. Indeed, our physician members routinely report challenges with current Medicare enrollment
requirements, which already impose a significant burden.
Read full letter here
