Nov. 20, 2017
The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
Submitted electronically: https://www.surveymonkey.com/r/macra-cost-measures-field-testing
Re: MACRA Episode-Based Cost Measures Field Testing
Dear Administrator Verma:
The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the Centers for Medicare & Medicaid Services’ (CMS’) request for feedback regarding eight episode-based cost measures for potential use in the cost performance category of the Merit-based Incentive Payment System (MIPS), released Oct. 16, 2017.
MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA empowers medical group practices to create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.