August 2, 2022
The Honorable Xavier Becerra
Secretary
U.S. Department of Health and Human Services
200 Independence Ave, SW
Washington, DC 20201
The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
200 Independence Ave, SW
Washington, DC 20201
RE: Appropriate Implementation Timeline for Requirements under the No Surprises Act
Dear Secretary Becerra and Administrator Brooks-LaSure:
As the U.S. Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) continue to develop and implement requirements under the No Surprises Act, the Medical Group Management Association (MGMA) urges you to continue utilizing the Department’s enforcement discretion and provide medical group practices with at least 6 months final notice prior to the enforcement of any additional surprise billing requirements.