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    May 30, 2019   
    The Honorable Seema Verma
    Administrator Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    200 Independence Avenue, SW
    Washington, DC 20201 
    Submitted via email at 
    Re: Geographic PBP RFI 

    Dear Administrator Verma: 
    The Medical Group Management Association (MGMA) appreciates this opportunity to provide feedback regarding the Direct Contracting (DC) Geographic Population-based Payment (PBP) model. We support the Centers for Medicare & Medicaid Services’ (CMS) goal of increasing participation in Advanced Alternative Payment Models (APMs) by creating additional opportunities that encourage provider flexibility and choice and reduce burdensome regulations and one-size-fits-all requirements. MGMA commends CMS for seeking stakeholder input at the outset of DC Geographic PBP model development, and we look forward to an ongoing, constructive dialogue as model details are refined.  
    MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, people, insights, and advocacy, MGMA empowers medical group practices to innovate and create meaningful change in healthcare. With a membership of more than 45,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 practices of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States. 
    Before commenting specifically on the draft Geographic PBP option, the Association wishes to emphasize our support for CMS’ recent announcement creating more voluntary Advanced APMs through the Primary Care First (PCF) and DC models. MGMA continues to support the clear objective of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) to incentivize physician group practices to embrace alternatives to fee-for-service and incur greater performance risk for clinical outcomes and the cost of care. Unfortunately, physician group practices have limited opportunities to move into an Advanced APM. CMS estimates that less than 220,000 clinicians will become qualifying participants in Advanced APMs this year, compared to the 798,000 clinicians expected to participate in the Merit-based Incentive Payment System (MIPS). Many practices are interested in joining an APM, but are unable to do so because there are not viable options for practices of their size, specialty, or location. In a 2018 survey of MGMA members, 55% of over 400 respondents reported that Medicare does not offer an Advanced APM option that is clinically relevant to their practice.2  
    We are encouraged by the potential of new models to support physician group practices that currently have few APM opportunities. MGMA urges CMS to consider the following principles for encouraging physician practice participation and allowing for their success in a DC model:

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