December 19, 2019
The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
202 Independence Avenue, S.W., Room 445-G
Washington, D.C. 20201
Re: CMS-1720 Medicare Program; Modernizing and Clarifying the Physician Self-Referral Regulations
Dear Administrator Verma,
The Medical Group Management Association (MGMA) is pleased to submit the following comments to the Centers for Medicare & Medicaid Services (“CMS” or “the Agency”) on its proposed rule modernizing and clarifying the Physician Self-referral (“Stark”) Law. We appreciate the Agency’s recognition that the Stark Law must be revised to remove barriers to value-based payment reform and its acknowledgment that the physician community needs greater clarity and certainty regarding several exceptions and definitions in the current regulations.