Abe Sutton, J.D.
Deputy Administrator and Director, Center for Medicare & Medicaid Innovation
Centers for Medicare & Medicaid Services (CMS)
200 Independence Avenue, SW
Washington, DC 20201
Dear Director Sutton,
Thank you for meeting with representatives from the Surgical Coalition on August 14, 2025, to discuss the Center for Medicare & Medicaid Innovation (CMMI) Wasteful and Inappropriate Service Reduction (WISeR) Model. We write to follow up on that conversation and highlight several areas where greater clarity, transparency, and accountability are needed as the WISeR model gets underway on January 1, 2026. Many of these issues have not yet been addressed or were addressed only briefly in the WISeR Provider and Supplier Operational Guide (the Operational Guide).1 We also offer suggestions for how CMMI might approach both initial implementation and ongoing oversight of the model.
In summary, we offer comments on the following areas where we believe additional clarity on various processes would support the model’s success:
- Communication from participants to providers
- Ongoing transparency and feedback to providers
- Transparent criteria and algorithms
- Non-affirmations
- Audit process and monitoring
- Reporting of performance metrics, outcomes, and provider/supplier and beneficiary
experience - Prior authorization of facility-based services
- Third party evaluation
- Participant payment incentives
We also recommend refinements to the model in the following areas:
- Gold carding
- Implementation of an annual fee-based structure
- 6-month soft launch
- Process for removing items from the prior authorization list
Click here to view the full Physician Organizations Urge CMMI to Clarify and Strengthen Oversight of the WISeR Model
