Ms. Alleyne and Ms. Doyle are attorneys at Memphis, Tenn.-based Baker Donelson, one of the largest law firms in the nation. Some of the sections of the plan lacking details, according to Ms. Alleyne and Ms. Doyle, include privacy concerns from new data elements, reviewing conditions for participation and/or coverage, and the effect on providers.
“CMS’ next iteration of guidance regarding its framework should provide more detailed information regarding the initiative’s legal and administrative impacts so that providers can assess the potential effects of the proposed solutions and better assist CMS in achieving its crucial goals,” they wrote.
“Until then, healthcare organizations and providers seeking to partner with CMS in its efforts to improve health equity and reduce health disparities will be left in search of a destination without a map.”
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