Final Waivers in Connection with the Medicare Shared Savings Program

Dear Ms. Tavenner and Mr. Levinson: On behalf of the Advanced Medical Technology Association (AdvaMed), I am pleased to offer comments on the interim final rule with comment period (IFC) entitled "Medicare Program: Final Waivers in Connection with the Shared Savings Program," published in the Federal Register on November 2, 2011. AdvaMed greatly appreciates this opportunity to comment. AdvaMed member companies produce the medical devices, diagnostic products and health information systems that are transforming health care through earlier disease detection, less invasive procedures, and more effective treatments. These products and services improve patient care quality. In addition, they often improve efficiency by reducing the lengths of stay, allowing procedures to be performed in less intensive and less costly settings, providing early detection of disease and infections, and improving the ability of providers to monitor care, among other benefits. AdvaMed members range from the largest to the smallest medical technology innovators and companies. In the attached letter, AdvaMed provides general comments on the waivers and responds to specific requests for comment regarding the particular waivers established under the IFC.