Comment Letters Recently Submitted 

On December 31, 2019, LUGPA sent comment letters to the Department of Health and Human Services and the Centers for Medicare & Medicaid Services regarding the Anti-Kickback Statute Proposed Rule and the Stark Proposed Rule (respectively).  

The letter regarding the Anti-Kickback Statute states, "AKS14 has not kept pace with the evolution of care delivery models and payment paradigms established since passage of MACRA more than four years ago. The lack of modifications to these laws has been particularly harmful to independent specialty practices and the patients we serve. The need for reform is evident as studies are confirming that independent practices are commonly the highest value site-of-service."     

The letter regarding the Stark Proposed Rule imparts why it is so important for CMS, when finalizing the Proposed Rule, to ensure that the new exceptions and revisions to key terminology in the Stark regulations promote the role of independent practices in value-based care delivery. 

To learn more about LUGPA's stance on these issues, click here.