Comments to MCIT Interim Final Rule

The Coalition submited comments to CMS' Interim Final Rule regarding Medicare Coverage of Innovative Technology (MCIT). The Coalition applauded CMS for the rule getting innovative technologies to market faster. However, the Coalition raised concerns about issues surrounding the reasonable and necessary definition and counseled the Agency: "This portion of the rule should have been issued as a stand-alone proposal as the nature of it is separate from the MCIT rule and applies more broadly in the Medicare program. We recommend that the definition of reasonable and necessary be removed from the MCIT final rule so as to not further delay the implementation of the MCIT pathway. Then CMS can issue a stand-alone proposed rule to address the complexities of the reasonable and necessary definition by providing more clarification and addressing all the gaps that were contained in this proposal."
Read Coalition comments