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    September 1, 2022 

    The Honorable Chiquita Brooks-LaSure
    Centers for Medicare and Medicaid Services
    U.S. Department of Health and Human Services
    Attention: CMS-1770-P

    RE: Medicare Shared Savings Program Changes in the Physician Fee Schedule Proposed Rule

    Dear Administrator Brooks-LaSure:

    On behalf of the undersigned organizations, we applaud you for taking steps to reach the goal of creating a stronger Medicare program by strengthening accountable care models and speeding the movement toward value for all patients. We appreciate that many of the proposed changes in this rule are responsive to recommendations we have made for improving the Medicare Shared Savings Program (MSSP). Ultimately, many of these proposals will help grow participation in accountable care organizations (ACOs) and realize CMS’s stated goal to have all Medicare beneficiaries in a relationship with a provider who is responsible for quality and total cost of care. Additionally, these proposals will build on the current financial success of the program, saving Medicare more than $15 billion and yielding more than $650 million in shared savings to ACOs. We appreciate that CMS has thoughtfully considered how to improve the program; below we offer recommendations in response to the proposals.


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