American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

Regulatory Advocacy

Private Payors

ACS Advocacy

ACS Letter to CMS Regarding Private Payor Price Transparency

The ACS commented on the Centers for Medicare & Medicaid Services’ (CMS) Transparency in Coverage proposed rule, through which the Agency solicited input on approaches to make health care price information accessible to consumers. In its letter, the College offered guidance to CMS on methods to enhance the usability and accuracy of cost-sharing data presented by private payors to their enrollees.

Read the Transparency in Coverage letter

ACS Letter to Anthem on Erroneous Coverage/Reimbursement Policies

In 2018, the College sent a letter to Anthem leadership expressing concern with several coverage and reimbursement policies that would put patient safety at risk, inappropriately shift costs onto enrollees, delay the provision of necessary care, and unfairly cut physician payment.

Read ACS letter to Anthem

Regulatory Advocacy

COVID-19 Pandemic

Program Integrity

The ACS commented on the Centers for Medicare & Medicaid Services’ (CMS) 2019 request for information (RFI) on the future of program integrity under the Medicare program. In its letter, the College urged CMS to establish policies to ensure access to care in value-based payment arrangements, increase the accuracy and accessibility of provider directories, and address the overwhelming burden of prior authorization and re-certification of medical necessity.

Read the Program Integrity letter

Health Information Technology

ACS Letter to ONC on the Federal Health IT Strategic Plan

The ACS commented on the Office of the National Coordinator for Health Information Technology (ONC) 2020-2025 Federal Health IT Strategic Plan, as well as the roadmap the Agency put forth to achieve these goals. Within the 2020-2025 Strategic Plan, ONC highlighted the principles that were at the center of the development of the plan, including, putting the individual first: “embrace person-centered care that values the whole individual, including their goals, values, culture, and privacy.” The College supported the overarching goals and objectives of this plan, highlighting the need for patient-focused solutions that assure the security and privacy of patient data. ACS also highlighted how the advanced use of health IT presents opportunities to increase value of healthcare while reducing costs, as well as further the role of the patient in care management.

Read the ONC Federal Health IT Strategic Plan letter

ACS Letter to FDA to Modernizing the FDA Data Strategy

The ACS submitted comments to the Food and Drug Administration (FDA) Modernizing the Food and Drug Administration’s Data Strategy public workshops and topics for discussion. The ACS urged the Agency to seek opportunities and develop policies that support the importance of common data standards to support shared interoperability. The College also emphasized the need for keeping the patient at the forefront and consider the careful balance between technology solutions that assure patient data remain secure while simultaneously meeting the challenge of leveraging those data to improve clinical care.

Read the FDA Data Modernization letter

ACS Letter to the FTC on Health Breach Notification Rule

The ACS commented on the Federal Trade Commission (FTC) Health Breach Notification (HBN) Rule proposed rule, which would update the Agency’s privacy and security standards to ensure patients are aware when their personal health record information is accessed or acquired inappropriately. The ACS addressed many questions posed by the FTC, supporting its efforts to keep patients’ identifiable health information safe as the use of direct-to-consumer technologies become more commonplace.

Read the FTC Health Breach Notification letter

ACS Letter to the ONC regarding Patient Identity and Matching Solutions

The ACS submitted comments to the ONC’s 2020 RFI focused on Patient Identity and Matching issues. The ACS comments included considerations and potential solutions to allow for the accurate and reliable matching of patient information.

Read the ONC Patient Identity and Matching letter

Stark Law & Anti-Kickback Statute

ACS Letters to CMS Regarding the Physician Self-Referral Law

In December 2019, the ACS submitted letters in response to proposed rules issued by CMS and Office of the Inspector General (OIG) regarding the Anti-Kickback Statute (AKS) and physician self-referral law (the “Stark Law”), through which the agencies sought stakeholder feedback on revisions to such regulations. In its letters, the College provided input on AKS safe harbors and Stark Law exceptions for certain types of compensation arrangements.

Read the Stark Law letter to CMS

Read the AKS letter to the OIG

Other Regulatory Advocacy 

ACS Letter to CMS Regarding the No Surprises Act 

The ACS submitted comments in response to proposed rules issued by the U.S. Department of Health and Human Services, the U.S. Department of Labor, and the U.S. Department of the Treasury implementing the No Surprises Act. 

Read the first Surgical Coalition Sign-on Letter on the No Surprises Act

Read the second Surgical Coalition Sign-on Letter on the No Surprises Act

Read the ACS comment letter on the good faith estimate provisions of the No Surprises Act Interim Final Rule