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    November 15, 2022 

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

    Re: CMS-9900-NC; Request for Information; Advanced Explanation of Benefits and Good Faith Estimate for Covered Individuals

    Dear Secretary Becerra,

    The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the request for information (RFI) from the Department of Health and Human Services, the Department of the Treasury, and the Department of Labor (the Departments) regarding rulemaking for the advanced explanation of benefits (AEOB) and good faith estimate (GFE) requirements of the No Surprises Act.
    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.

    The No Surprises Act established critical patient protections against balance billing and created new cost transparency tools to help empower patients to be better informed while making healthcare decisions. On Jan. 1, 2022, several provisions of the No Surprises Act took effect, including the uninsured and self-pay good faith estimate (GFE) requirements. Although MGMA supports the spirit of the law, we have concerns about the way certain provisions will be implemented due to the limitations of the current healthcare environment and available infrastructure.


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