Chairman Hatch, Ranking Member Wyden, and members of the Committee, the Alliance of Specialty
Medicine (the Alliance) would like to thank the Senate Committee on Finance for the opportunity to
provide feedback on implementation of the Medicare Access and CHIP Reauthorization Act of 2015
(MACRA). The Alliance strongly supports your involvement in ensuring that the Centers for Medicare
and Medicaid Services (CMS) follows the legislative intent of MACRA as CMS undergoes rulemaking
to implement its provisions. The Alliance is a coalition of medical specialty societies representing more
than 100,000 physicians and surgeons from specialty and subspecialty societies dedicated to the
development of sound federal health care policy that fosters patient access to the highest quality
specialty care.
Member organizations of the Alliance have continuously sought out and developed robust mechanisms
(including clinical decision support, clinical data registries, and other tools) aimed at improving the
quality and efficiency of care specialty physicians provide. In addition, Alliance member organizations
have analyzed and heavily scrutinized data related to the services they provide, looking for ways to
improve how they diagnose, treat, and manage some of the most complex health care conditions in their
respective specialty areas. With those sentiments in mind, the Alliance is eager to engage in programs
that would further these efforts with incentives and technical assistance.\
However, despite the considerable and often overwhelming effort the Alliance put into helping shape
provisions in the MACRA legislation, as well as the ongoing feedback provided during the many pre-rulemaking comment and feedback opportunities, we are concerned that several of the principles we
have long supported and conveyed to the agency were largely ignored. This is particularly true when it
comes to proposals associated with the use of electronic health records (EHRs), the application of
socioeconomic risk factors in quality and cost metrics, and most importantly, substantial disparities in
Quality Payment Program (QPP) requirements that significantly disadvantage specialty care providers
and the patient populations they serve. We hope that our comments herein will move CMS to address
some of the most pressing issues facing specialty medicine, removing barriers that limit meaningful
specialty physician engagement, and offering all specialists and non-specialists equal opportunities to
demonstrate quality in a relevant manner.
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