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Seema Verma, MPH
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1701-P, Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

RE: Medicare Program; Medicare Shared Savings Program; Accountable Care OrganizationsPathways to Success

Dear Ms. 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 proposals aimed at redesigning and providing a new direction for the Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs).

General Concerns

Specialist Participation in ACOs

Despite a recent Medicare Payment Advisory Commission (MedPAC) analysis that found sixty percent (60%) of ACO-participating physicians are specialists1, the Alliance remains concerned that many ACOs have adopted “narrow networks” to inappropriately limit specialty physician participation. The lack of “network adequacy” standards allows this primary care-dominated model to essentially “bar” the participation of specialists, even when specialty physicians express an interest in joining the model.

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