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    December 20, 2023 

    The Honorable Xavier Becerra
    U.S. Department of Health and Human Services
    200 Independence Ave, SW
    Washington, DC 20201

    The Honorable Chiquita Brooks-LaSure
    Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    RE: Federal Independent Dispute Resolution Operations (RIN 0938–AV15)

    Dear Secretary Becerra and Administrator Brooks-LaSure:

    On behalf of our member medical group practices, the Medical Group Management Association (MGMA) is pleased to submit comments in response to the Federal Independent Dispute Resolution Operations proposed rule, published in the federal register on Nov. 3, 2023.

    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 feedback.

    The No Surprises Act (NSA) was passed by Congress as part of the Consolidated Appropriations Act, 2021, and created certain patient protections from surprise medical bills. MGMA supports protecting patients’ access to necessary care while creating a pathway to ensure physicians and practices receive appropriate payment for out-of-network services.

    Since its inception, the Independent Dispute Resolution (IDR) process has placed substantial administrative burden on medical groups, created an imbalance of power between the provider and insurer parties, and threatened the financial viability of certain physician practices. A recent Government Accountability Office (GAO) report highlights many of the challenges medical groups are experiencing with the implementation of the NSA. Unsurprisingly, the report found that initiating parties (mainly providers) prevailed in 77% of disputes initiated between Jan. 1 and June 30, 2023.1 This further underscores the legitimacy of provider-initiated disputes, and the need to ensure the IDR process is fair and equitable.


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