Comment Letter

Neurosurgery Comments on Network Adequacy

  • Health Care Competition
  • Reimbursement and Practice Management

Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-9899-P
P.O. Box 8016
Baltimore, MD 21244-8016

RE: Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2024

Dear Administrator Brooks-LaSure,

The Alliance of Specialty Medicine (the “Alliance”), representing more than 100,000 specialty physicians from sixteen specialty and subspecialty societies, is deeply committed to improving access to specialty medical care by advancing sound health policy. On behalf of the undersigned members, we write to express ongoing concern with network adequacy in Marketplace plans and other issues.

In this rule, CMS proposes to require all Exchange plans to comply with its existing standards for network adequacy, including those that have not used a provider network. The Alliance appreciates that all plans would be subject to network adequacy standards. However, we remain concerned that CMS’ existing network adequacy standards fail to meaningfully ensure robust access to specialty and subspecialty medical care.

Click here to read the full Neurosurgery Comments on Network Adequacy.