The Alliance of Specialty Medicine submitted comments in response to the CMS final rule with comment period requiring disclosure of affiliations for certain Medicare providers and suppliers.  While acknowledging appreciation for CMS’ final policy to phase-in disclosure requirements, the Alliance expressed concern that the finalized requirements are still overly burdensome and that physicians will experience difficulty identifying and tracking required affiliations when they are required to do so.  The Alliance urged CMS to evaluate the usefulness of the data collected to determine whether changes can be made to reduce reporting requirements in the future, particularly for low-risk providers and suppliers, and to work with stakeholders in the development of subregulatory guidance.  The Alliance also urged CMS to implement future phases gradually over time and to prioritize collection of affiliation data from those providers and suppliers who present the greatest risk to the Medicare, Medicaid, and CHIP programs.

Alliance Letter to CMS on Provider Integrity and Eligibility