December 15, 2016: MGMA comments on the development of a new Medicare ACO model, Track 1 Plus (1+)

December 15, 2016 

Mr. Andrew Slavitt 
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20201

Re: (CMS-5517-FC) Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician- Focused Payment Models

Dear Acting Administrator Slavitt:

The undersigned organizations submit the following comments and recommendations for developing a new Medicare ACO model, Track 1 Plus (1+), as discussed in the final rule with comment period, Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician- Focused Payment Models, published in the Federal Register on November 4, 2016. The signatories to this letter include organizations representing physicians, hospitals, medical group practices, academic medical centers and nearly all existing Medicare Shared Savings Program (MSSP) ACOs.

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