September 3, 2021
The Honorable Xavier Becerra
Secretary
U.S. Department of Health and Human Services
200 Independence Ave, SW
Washington, DC 20201
The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
200 Independence Ave, SW
Washington, DC 20201
RE: Requirements Related to Surprise Billing; Part 1 [CMS-9909-IFC]
Dear Secretary Becerra and Administrator Brooks-LaSure:
The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the interim final rule with comment entitled, “Requirements Related to Surprise Billing; Part I,” file code CMS-9909-IFC.
Explore Related Content
Federal Policy Resource
Analysis: Proposed 2022 Medicare Physician Payment and Quality Reporting Changes
Federal Policy Resource
MGMA 2018 Regulatory Burden Report
Federal Policy Resource
MGMA AUC Toolkit
Federal Policy Resource
MGMA Annual Regulatory Burden Report - 2019
Federal Policy Resource
Analysis: Final 2021 Medicare Physician Payment and Quality Reporting Changes
Federal Policy Resource
MGMA Government Affairs Information Blocking Webinar with ONC
Federal Policy Resource
GovChat Live: Review of the 2022 Medicare PFS proposed rule
Federal Policy Resource
Analysis: Final 2022 Medicare Physician Payment and Quality Reporting Changes
Federal Policy Resource
MGMA in Washington: 2021 Year in Review
Federal Policy Resource
MGMA Annual Regulatory Burden Report - 2022
Federal Policy Resource
Provisions Impacting Medical Groups in the Consolidated Appropriations Act, 2023
Federal Policy Resource
Analysis: Final 2023 Medicare Physician Payment and Quality Reporting Changes
Federal Policy Resource
2022 MGMA in Washington Year in Review
Federal Policy Resource
Updated: Flexibilities and policy following the expiration of the COVID-19 PHE
More Advocacy Letters
Advocacy Letter
MGMA Supports the Safe Step Act (October 22, 2025)
Advocacy Letter
MGMA Joins Letter on DEA Telehealth Extension (July 22, 2025)
