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    December 19, 2019  

    The Honorable Seema Verma
    Administrator
    Centers for Medicare & Medicaid Services
    Hubert H. Humphrey Building
    202 Independence Avenue, S.W., Room 445-G
    Washington, D.C. 20201

    Re: CMS-1720 Medicare Program; Modernizing and Clarifying the Physician Self-Referral Regulations

    Dear Administrator Verma,

    The Medical Group Management Association (MGMA) is pleased to submit the following comments to the Centers for Medicare & Medicaid Services (“CMS” or “the Agency”) on its proposed rule modernizing and clarifying the Physician Self-referral (“Stark”) Law. We appreciate the Agency’s recognition that the Stark Law must be revised to remove barriers to value-based payment reform and its acknowledgment that the physician community needs greater clarity and certainty regarding several exceptions and definitions in the current regulations.
     

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