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    April 16, 2024 

    William N. Parham, III
    Director, Division of Information Collections and Regulatory Impacts
    Office of Strategic Operations and Regulatory Affairs
    Room C4-26-05
    Centers for Medicare and Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244-1850

    Re: Prior Authorization Demonstration for Certain Ambulatory Surgical Center Services (CMS-10884)

    Dear Director Parham:

    On behalf of our member medical group practices, the Medical Group Management Association (MGMA) is pleased to provide the following comments in response to the Centers for Medicare and Medicaid Services’ (CMS) prior authorization demonstration for certain ambulatory surgical center (ASC) services. MGMA is concerned about CMS extending prior authorization requirements for ASCs under traditional Medicare and recommends the agency not move forward with this demonstration project.

    With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 group medical practices ranging from small private medical practices to large national health systems, representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following policy recommendations.

    CMS proposes to undergo a five-year demonstration project in ten states requiring prior authorization for certain surgical procedures provided in ASCs for traditional Medicare. The agency’s basis for the project is data from 2019-2021 that shows an increase in utilization for 40 procedures. CMS also discusses the need for the project due to concerns about fraud or abuse.

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