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    September 11, 2023 

    Consumer Financial Protection Bureau
    1700 G Street, NW
    Washington, DC 20552

    Re: Request for Information Regarding Medical Payment Products, Docket No. CFPB-2023-0038

    To Whom it May Concern:

    On behalf of our member medical group practices, the Medical Group Management Association (MGMA) thanks you for the opportunity to comment on the Consumer Financial Protection Bureau, Department of Health and Human Services, and Department of Treasury’s (collectively the agencies) joint Request for Information (RFI) regarding medical payment products. MGMA appreciates the agencies’ interest in seeking to understand the effects of medical payment products on patients and the healthcare system. As healthcare leaders, we want to underscore our commitment to providing high-quality, cost-effective, and timely patient care. Any utilization of these products is done with this in mind. MGMA is pleased to share feedback on how these payment products intersect with group practices.

    With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical groups in which more than 350,000 physicians practice. These groups range from small private practices in rural areas to large regional and national health systems, and cover the full spectrum of physician specialties and organizational forms, making MGMA well-positioned to offer the following feedback.

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