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    January 16, 2018  

    The Honorable Seema Verma, MPH
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    2000 Independence Avenue, SW
    Washington, DC 20201
    RE: Proposed Policy Changes and Updates for Medicare Advantage and the Prescription Drug Benefit Program for Contract Year 2019 (CMS-4182-P)
    Dear Administrator Verma: 

    The Medical Group Management Association (MGMA) submits the following comments in response to the proposed rule entitled, “Medicare Program; Contract Year 2019 Policy and Technical Changes to the Medicare Advantage, Medicare Cost Plan, Medicare Fee-for-Service, the Medicare Prescription Drug Benefit Programs, and the PACE Program,” published on Nov. 16, 2017, with file code CMS-4182-P. 

    MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA empowers medical group practices to create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.
    Implementation of Medicare Part D Drug Management Programs 
    While MGMA recognizes that steps need to be taken to address the nation’s opioid epidemic, we urge the Centers for Medicare & Medicaid Services (CMS) to balance this against the potential administrative and clinical burden on medical practices that may result from these proposed new drug management protocols. Among other proposals, CMS proposes to perform more frequent prescriber credentials checks and inquiries into the appropriateness, medical necessity and dosage of the prescription, as well as requiring sometimes numerous phone conversations between the prescribing clinician and the sponsor or other clinicians prescribing medications to the same patient. Any one of these could pose an undue administrative burden on the prescribing clinician and possibly delay patient access to critical medications and we urge CMS to keep this important consideration in mind and to keep required paperwork and phone conversations to an absolute minimum.

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