November 5, 2020
The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
RE: 2018 Advanced APM Payments
Dear Administrator Verma:
The Medical Group Management Association (MGMA) is writing regarding CMS’ policy to establish a deadline of Nov. 13 for qualifying participants (QPs) in alternative payment models (APMs) to provide updated billing information if they are identified in CMS’ QP Public Notice File as being unpaid. We respectfully request that the agency revise its decision to implement a deadline to claim missing 2018 APM payments; instead, CMS should remove the deadline all together. If CMS believes a cutoff date is necessary, then we urge the agency to establish a deadline of Dec. 31, 2020, at the earliest.