Open comment period closes Dec. 31

The Administration is seeking comment from the public and health professionals on a proposed regulation that could signficantly impact independent doctors. AID has submitted a comment, and we invite you to do the same.

The "Innovative Payment Reform" rule would relax Stark and Federal anti-kickback laws to "better pave the way for value-based payment models." AID is opposed, as we believe the move would pave the way for further hospital-doctor consolidation.

You may read our opinion here, and submit your own here: You will be commenting on the proposed rule titled: Medicare Program: Modernizing and Clarifying the Physician Self-Referral Regulations (CMS-1720-P)

Though the best comments are original and based on your experience, feel free to use parts of our opinion or the talking points below:

The proposed solution to relax Stark and anti-kickback laws will fuel further consolidation in health care.

Hospital consolidation, namely buying up independent medical practices, drives up costs, reduces competition, lowers quality and burns out doctors.

The move to soften physician referral law is based on the presumptive move to value-based care. While a system that ties payments to outcomes makes for good political theory, practically speaking, no one knows how to measure value.

Any reform aimed at increasing value needs to include complete price transparency. Consumers need to know where their health-care dollars are going, so they can make purchasing decisions based on cost and quality.

Medical decisions need to be kept separate from monetary gain.

Deregulating Stark law will give hospitals more leverage in an arena where they already have too much control.

Comments for this rule are due by Dec. 31, 2019.