April 21, 2023
The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244-1850
Re: CMS-0053-P, Administrative Simplification: Adoption of Standards for Health Care Attachments Transactions and Electronic Signatures, and Modification to Referral Certification and Authorization Transaction Standard
Dear Administrator Brooks-LaSure:
On behalf of our member medical group practices, the Medical Group Management Association (MGMA) thanks you for the opportunity to provide comments on the Centers for Medicare & Medicaid Services’ (CMS’) Notice of Proposed Rule Making on Administrative Simplification (“proposed rule”). These proposed changes are a critical first step in implementing long-needed updates to the Health Insurance Portability and Accountability Act (HIPAA) attachment standards and reducing significant administrative burden for medical groups.
With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups in which more than 350,000 physicians practice. These groups range from small private practices in rural areas to large regional and national health systems, and cover the full spectrum of physician specialties and organizational forms, making MGMA well-positioned to offer the following feedback.
April 21, 2023