MGMA Letter Archive

MGMA's Government Affairs department has been working to represent the interests of group practice administrators for 15 years. Below is an archive of our letters and advocacy efforts sent to the White House, Congress, and other regulatory entities.


  • MGMA comments in response to RFI on CMMI's new direction
  • MGMA submitted comments to CMS regarding its testing of eight episode-based cost measures and related feedback reports
  • MGMA sends letter to Congressional leadership supporting the elimination of the Independent Payment Advisory Board (IPAB)
  • MGMA sends letter to CMS expressing concern about the Clinical Laboratory Fee Schedule (CLFS)
  • MGMA sends letter to Congressional leadership on CSR payments and marketplace stabilization
  • MGMA comments on proposed cancelation and scaling back of several mandatory bundled payment models
  • MGMA joins other medical associations asking CMS to delay implementation of the revised CLFS rates mandated by PAMA
  • MGMA joins other medical associations to urge Congress to ensure CMS has implementation flexibility with the Quality Payment Program (QPP)
  • MGMA sends letter to Senate leadership regarding the Graham-Cassidy Amendment
  • MGMA joins other medical associations to express concern over PAMA implementation and its estimated detrimental impact on physician office laboratories.
  • MGMA submitted a detailed comment letter in response to the proposed 2018 Physician Fee Schedule and, in response to CMS’ request for information, outlined opportunities for the administration to relieve regulatory burdens on medical group practices, using MGMA’s 2017 Regulatory Burdens Survey results as a guide.
  • MGMA submits comments in response to proposed 2018 Quality Payment Program rule
  • MGMA supports coalition effort calling for electronic attachment standards
  • MGMA sends letter to Senate leadership regarding the Better Care Reconciliation Act (BCRA)
  • MGMA signs on to letter calling for CMS to modify the repayment mechanism requirements for two-sided ACOs so that they may participate in Track 1+
  • MGMA submits comments on the Medicare Inpatient Prospective Payment System (IPPS) and outlines concerns regarding government overreach with respect to the Meaningful Use EHR Incentive Program
  • MGMA joins several provider organizations urging CMS to include group practices in alternative payment models (APMs) with Medicare Advantage plans in the APM track of MACRA
  • MGMA and coalition send letter to CMS expressing concern over planned enactment of the Social Security Number Removal Initiative (SSNRI)
  • MGMA sends letter to Congress in support of the CONNECT for Health Act, which would expand coverage for telehealth services
  • MGMA submits comments calling on CMS to pilot test new QPP episode-based cost measures through a voluntary program to mitigate any unintended consequences
  • MGMA signs on to letter to CMS requesting they delay the implementation of PAMA reporting requirements for labs
  • MGMA joins health industry in support of the Labor-H report language on patient matching
  • MGMA sends letter to House leadership expressing concerns regarding the American Health Care Act (AHCA)
  • MGMA and coalition urge CMS to minimize penalties resulting from the final year of the Meaningful Use, PQRS, and Value-Based Payment Modifier programs
  • MGMA calls on CMS for past-due MIPS eligibility notifications
  • MGMA submits comment letter to FCC defending practices' ability to send billing communications to patients
  • MGMA calls for delay in 2015 Edition Certified EHR
  • MGMA highlights opportunities for regulatory relief in letter to new HHS Secretary Dr. Tom Price
  • MGMA joins coalition effort voicing prior authorization principles



  • MGMA comments on the development of a new Medicare ACO model, Track 1 Plus (1+)
  • MGMA submits comments on MIPS/APMs final rule
  • MGMA letter to CMS: extend 2017 PQRS informal review deadline and allow for manual review of erroneous automatic denials
  • MGMA comments on 2017 OPPS Meaningful Use provisions
  • MGMA submits formal comments in response to the release of the Proposed 2017 Medicare Physician Fee Schedule
  • MGMA joins industry coalition letter raising concerns over implementing policy to remove social security numbers from all Medicare ID cards without allowing a formal public comment period for industry feedback. 
  • MGMA to CMS in letter: Improve accuracy, reduce burden in draft MIPS patient attribution methodology
  • MGMA joined more than 100 physician specialty and state medical organizations in urging CMS to increase flexibility and decrease burdens in MIPS and provide a more robust APM pathway
  • MGMA shared concerns with CMS about the proposed framework for MIPS and APMs and offered recommendations to improve and simplify these programs
  • MGMA encouraged the Physician-Focused Payment Models Technical Advisory Committee to consult physician administrators in its review of payment model proposals
  • MGMA expressed concerns with the Medicare Part B Drug Payment Model proposed rule to the Centers for Medicare & Medicaid Services
  • MGMA wrote a letter to CMS addressing a proposed rule on program integrity enhancements to the provider enrollment process for Medicare, Medicaid, and the Children’s Health Insurance Program (CHIP)
  • MGMA, along with 21 other organizations, urged CMS to modify the ACO benchmarking methodology and further refine the Medicare Shared Savings Program to ensure greater participation
  • MGMA joined 33 other organizations in a letter to CMS, calling for a 90-day reporting period for the 2016 Meaningful Use EHR incentive program
  • MGMA wrote a letter of support for the Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act (S. 2484) which expands coverage for telehealth services by lifting a number of Medicare’s restrictive coverage requirements for these convenient and flexible services
  • MGMA to CMS: increase physician input and transparency in development of resource utilization measures under the new Merit-Based Incentive Payment System (MIPS)
  • MGMA and other physician specialty organizations submit a letter to CMS underscoring its inadequate feedback and informal review request processes for the PQRS Program
  • MGMA responds to the solicitation of comments from the Senate Committee on Finance and the House Committee on Ways and Means on how the Stark law might be improved
  • MGMA submits letter to Senate Committee on Finance’s Chronic Care Working Group Policy Options document on Chronic Care Management services and ACO policies
  • MGMA joins other stakeholders to submit feedback to the Senate Finance Committee's Chronic Care Working Group on improving Medicare ACO policies



  • MGMA expresses concerns to CMS in response to the Medicare Clinical Diagnostic Laboratory Tests Payment System Proposed Rule
  • MGMA comments on a request for information from CMS regarding implementation of MIPS and APM programs under MACRA
  • MGMA submits a letter in support of H.R. 3940, which would ensure that the Centers for Medicare & Medicaid Services could grant broad relief to eligible professionals and other providers from the 2015 EHR Incentive (Meaningful Use) Program due to the delay in publication of the Stage 2 Meaningful Use rule
  • MGMA joined with more than 40 provider organizations calling on the Secretary of the Department of Health and Human Services (HHS) to take immediate action on the EHR Incentive Program (meaningful use)
  • MGMA submits formal comments in response to the release of the Proposed 2016 Medicare Physician Fee Schedule
  • MGMA joins other industry stakeholders to submit a letter urging the publication of the Final Rule on modifications to the meaningful use program
  • MGMA sends letter in support of legislation to increase meaningful use flexibility
  • MGMA responds to CMS' Request for Information regarding the Health Plan Identifier
  • MGMA submits formal comments in response to a CMS proposed rule modifying regulations governing Medicaid and CHIP
  • MGMA writes a letter in support of  the Coding Flexibility in Healthcare Act (H.R. 3018)
  • MGMA formally expresses its support for proposed modifications to Stage 2 of the Medicare EHR Incentive (meaningful use) Program and encourages expedited finalization of the proposed changes, which create more flexibility within the program.
  • MGMA submits formal comments in response to the Medicare EHR Incentive (meaningful use) Program Stage 3 Proposed Rule
  • MGMA joins 37 other provider organizations in a letter urging CMS to include physician-led organizations and specialty societies in the clinical quality measures development process for the new Merit-based Incentive Payment System
  • MGMA writes a letter urging Senators not to extend Medicare sequestration cuts to offset the cost of the Trade Adjustment Assistance program
  • MGMA publicly demonstrates its support for the SGR Repeal and Medicare Provider Payment Modernization Act of 2015 (H.R. 1470/S. 810), which would permanently repeal the flawed Medicare Sustainable Growth Rate (SGR) formula
  • MGMA collaborates with 25 other provider organizations in a letter to HHS highlighting concerns over certain appropriate use and prior authorization criteria included in the Protecting Access to Medicare Act
  • MGMA joined over 750 industry groups in sending this stakeholder letter to Speaker Boehner urging him to once and for all repeal the Medicare SGR formula before the current patch expires on March 31, 2015
  • MGMA expresses strong support for H.R. 1190, which would eliminate the Independent Payment Advisory Board (IPAB) created under the Patient Protection and Affordable Care Act (ACA)
  • MGMA comments on the draft 2016 Medicare Advantage and Part D Call Letter, urging more detailed information for denials and enhanced accuracy of provider directories
  • MGMA, along with 100 other provider organizations, raises concerns regarding critical ICD-10 issues
  • MGMA, along with 30 other organizations, sent a letter to the Centers for Medicare & Medicaid Services (CMS) urging the agency to strengthen standards for Medicare Advantage network adequacy
  • MGMA contributes to coalition effort making significant recommendations in response to changes set forth in the Medicare Shared Savings Program Accountable Care Organizations notice of proposed rulemaking. Read the full-length or short letter
  • MGMA urges CMS to alleviate administrative burden by streamlining access for multiple quality reporting programs into one portal
  • MGMA joins industry effort to outline concerns and provide recommendations to CMS in two key areas of administrative transactions; virtual credit cards and health plan identifiers on claims
  • MGMA teams with AMA, AHA and others to raise concerns with the proposal to require universal device identifiers on claim forms
  • MGMA collaborates with industry stakeholders on letter to National Coordinator for Health Information highlighting concerns over the trajectory of EHR certification and making several recommended improvements



  • MGMA sends letter to CMS bringing attention to the recent trend in "virtual" credit card payments and unecessary fees attributed to EFT transactions
  • MGMA comments on burdensome review process of Open Payments Program
  • MGMA sends letter of opposition to H.R. 4302, the "Protecting Access to Medicare Payment Act of 2014"
  • MGMA signs onto letter urging the Senate Finance Committee to preserve the in-office ancillary services exception to the Stark Law
  • MGMA comments on Medicare Advantage and Part D prescription drug benefit proposed rule
  • MGMA joins over 600 organizations in signing onto letter of support for the SGR Repeal and Medicare Provider Payment Modernization Act of 2014 (H.R. 4015/ S. 2000)
  • MGMA urges CMS to reconsider ACA 90-day grace period
  • MGMA signs onto letter underscoring concerns regarding compliance with the EHR Incentive Program
  • MGMA sends letter to express our support for H.R. 4015/S. 2000, otherwise known as the SGR Repeal and Medicare Provider Payment Modernization Act of 2014
  • MGMA signs onto letter demanding a comprehensive solution to the Medicare appeal backlog problem
  • MGMA signs onto letter congratulating Congressional leaders on their introduction of SGR repeal legislation







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