RE: Medicare Program; Request for Information Regarding the Physician Self-Referral Law
Dear Administrator Verma,
On behalf of more than 100,000 specialty physicians from 15 specialty and subspecialty societies, and
dedicated to the development of sound federal health care policy that fosters patient access to the
highest quality specialty care, the undersigned members of the Alliance of Specialty Medicine (the
“Alliance”) write in response to your request for information on addressing the undue regulatory impact
and burden of the physician self-referral law.
Impact and Burden of the Physician Self-Referral Law on Specialty Engagement in
Alternative Payment Model Development and Participation
Specialty physicians are an essential and needed component of the health care system and, particulary,
in the Medicare program. Specialists use their deep knowledge and expertise to reach a precise medical
diagnosis, present the full array of available interventions, collaborate closely with their patients to
determine the most appropriate option based on their preferences and values, and coordinate and
manage their specialty and related care until treatment is complete. The value of specialists cannot be
overstated nor can it be replaced by any other type of clinician, provider, or health care professional.
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