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Seema Verma
Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Attention: CMS-1720-NC, Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

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.

With those sentiments in mind, the Alliance is concerned with the lack of alternative payment models (APMs), particularly those that qualify as “advanced” under the Quality Payment Program (QPP), in which specialists can meaningfully engage. In addition, we are concerned that specialists’ attempts to develop APMs for certain conditions and procedures face insurmountable challenges, despite the pathway for their establishment under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). While there are a number of contributing factors for this, the Stark law is chief among them.

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