May 14, 2020
Ms. Seema Verma
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20201
Re: Supporting ACOs in Response to COVID-19 (CMS-1744-IFC and CMS-5531-IFC)
Dear Administrator Verma,
We thank the Centers for Medicare & Medicaid Services (CMS) for the significant efforts underway to address the COVID-19 pandemic, including expanded telehealth services and other flexibilities. The undersigned organizations write to provide feedback in response to the two interim final rules with comment period (IFCs) making policy and regulatory revisions related to the COVID-19 Public Health Emergency. These IFCs, CMS-1744-IFC, Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and CMS-5531-IFC, Medicare and Medicaid Programs, Basic Health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program, were published in the Federal Register April 6 and May 8, respectively. Our recommendations reflect our unified desire to see the Medicare Shared Savings Program (MSSP) achieve the long-term sustainability necessary to enhance care coordination for millions of Medicare beneficiaries, lower the growth rate of healthcare spending and improve quality of care.
May 14, 2020