April 30, 2004
Director, Division of Performance Evaluation Planning
Medicare Contractor Management Group
Centers for Medicare and Medicaid Services
Mail Stop S2-21-28
7500 Security Boulevard
Baltimore, MD 21244-1850
RE: Alliance of Specialty Medicine Comments on Section 911 of the Medicare Modernization Act (MMA)
Dear Ms. Lathroum:
The Alliance of Specialty Medicine (the Alliance) welcomes the opportunity to provide comments on the Centers for Medicare and Medicaid Services' (CMS) plans to implement Section 911 of the MMA. The Alliance was founded in 2001 to serve as a strong voice for specialty medicine and represents over 200,000 physicians in 14 medical specialty organizations. It is dedicated to addressing many of the complex and often controversial healthcare issues debated in Washington today. The sheer volume of provisions in the MMA and short timeframes for implementation make a collaborative approach with physicians and other health care providers imperative. The Alliance, therefore, appreciates Congress' including language requiring consultation with providers in Sec. 911.
This section establishes a competitive bidding process to replace the existing carrier and fiscal intermediary contracts with Medicare Administrative Contractors (MACs). The process should be in place by October 2005. The award of MAC contracts will end the historical separation of contractors administering Part A and Part B of the Medicare. It will change long-standing relationships with physicians, contractors, and CMS that are extremely complex and valuable. MACs will manage claims payment and medical review, appeals, local coverage decisions, physician education and technical assistance, and provider enrollment in the Program. Therefore, great care must be taken to establish contractor requirements and oversight processes that improve the current arrangements. We urge CMS to carefully consider the principles and concerns that the Alliance has outlined below:
The Alliance welcomes the opportunity to work with the CMS staff on all phases of the important changes in contractor activities. We look forward to commenting formally on the draft standards once they are published, as well as carefully reviewing your report to Congress and the General Accounting Office on implementation plans. Please contact Barbara Marone at firstname.lastname@example.org or at (202) 728-0610 or Patrice Drew at email@example.com or at (202) 428-4148 should you need additional information. Thank you for considering our views.
American Academy of Dermatology Association
American Association of Neurological Surgeons/Congress of Neurological Surgeons
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American College of Obstetricians and Gynecologists
American Gastroenterological Association
American Society for Clinical Pathology
American Society of Cataract & Refractive Surgery
American Urological Association
Society of Thoracic Surgeons
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