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    December 6, 2021 

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

    RE: Requirements Related to Surprise Billing; Part II [CMS-9908-IFC]

    Dear Secretary Becerra:

    The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the interim final rule (IFR) with comment entitled, “Requirements Related to Surprise Billing; Part II,” file code CMS-9908-IFC.

    With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups comprising more than 350,000 physicians. These groups range from small independent practices in remote and other underserved areas to large regional and national health systems that cover the full spectrum of physician specialties.


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