Comment Letter

Neurosurgery Urges CMS to Reduce Burdens Associated with APM Participation

  • Quality Improvement and Patient Safety

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G 200
Independence Avenue, SW
Washington, DC 20201

Dear Administrator Brooks-LaSure:

The undersigned, which include dozens of national physician organizations representing hundreds of thousands of physicians, as well as over one hundred Accountable Care Organizations (ACOs), health systems, hospitals, clinics, and practices from across the country write to express our unified, strong opposition to two recently finalized policies in the 2024 Medicare Physician Payment Schedule pertaining to certified electronic health record technology (CEHRT) utilization requirements for ACOs, Alternative Payment Model (APM) Entities, and their participating practices. We have serious concerns that these policies will significantly increase burden and jeopardize participation in the Medicare Shared Savings Program (MSSP) and other Medicare Advanced APMs with a disproportionate impact on small practices and the patients they serve.

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