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    March 2, 2020 

    The Honorable Seema Verma
    Administrator
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services 
    200 Independence Avenue, SW 
    Washington, DC 20201 

    RE: 2021 Medicare Advantage Star Rating Program

    Dear Administrator Verma:

    The Medical Group Management Association (MGMA) is pleased to submit the following response to the Centers for Medicare & Medicaid Services (CMS) proposed Advance Notice of Methodological Changes for Calendar Year (CY) 2021 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies – Part II. Specifically, we offer comments on the Potential New Measure Concepts related to the issue of prior authorization. We commend CMS for recognizing the need to improve the current prior authorization environment and seeking to leverage the Star Rating Program in pursuit of that important goal. 
     

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