Chairman Buchanan, Ranking Member Lewis, and members of the Subcommittee, the Alliance of
Specialty Medicine (the Alliance) would like to thank the House Ways and Means Oversight
Subcommittee for the opportunity to provide input on efforts by the Centers for Medicare and
Medicaid Services (CMS) to identify and combat waste, fraud, and abuse in the Medicare program.
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. As
patient and physician advocates, the Alliance welcomes the opportunity to provide input in the
formulation of health and Medicare policy.
While we recognize the importance of improving program integrity for Medicare to protect
taxpayer dollars, the Alliance is increasingly concerned with CMS’ approach to program integrity,
which places numerous, burdensome requirements on physician practices. These initiatives are
duplicative, disruptive to physician practices, and often lead to penalties based on technicalities or
inconsistent application of program requirements. CMS also provides little transparency with
respect to the scope, authority, and operations of initiatives they undertake, thereby creating
additional uncertainty for the physician community and limiting accountability for CMS and its
contractors.
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