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Testimony and Public Comment

Read about published PBGH commentary and responses to requests for public comment.



Elizabeth Mitchell sent a letter to the Senate HELP Committee on Tuesday, following her influential testimony at the Committee’s hearing on June 18.  She continued to push for an end to surprise billing (including air ambulances), a reasonable benchmark for physician payments, reductions in drug costs, prohibitions on anti-competitive provider contracting terms, increased transparency (including for PBMs), and improvements in maternal and child health.

Read and listen to PBGH President and CEO Elizabeth Mitchell’s testimony before the U.S. Senate HELP Committee on June 18th and hear her share how care should and can be high quality and affordable.

Members of PBGH join other employers and healthcare purchasers to stop the unfair and harmful surprise billing that takes place due to no fault of patients accessing healthcare that they believe is in-network, or for which they have no choice.  Read more here.


PBGH, along with 18 other consumers and purchasers, signed on to the C-P Alliance's comment letter on the FY2019 Medicare Inpatient Prospective Payment System (IPPS) proposed rule. This proposed rule represents some of the most significant changes to CMS's hospital and other inpatient programs since their inception. Through the C-P Alliance comment letter, we urge CMS to maintain the current systems for reporting quality measures while investing in technical and/or policy solutions that would allow providers to report a measure once for use in multiple programs. The proposed approach -- to reduce provider reporting burden by streamlining (i.e., removing or de-duplicating) measures across CMS's various hospital programs -- is short-sighted and threatens the public's right to quality transparency. Please find the comment letter here.

PBGH signed on to two letters in support of pending legislation H.R. 5138 which would expand HSA regulations to better enable access to primary care and chronic disease management. The letter directed to the Senate Finance Committee urged them to support changes to HSA regulations to allow greater flexibility to offer first-dollar coverage of services and medications for chronic disease prevention; and the letter directed to the House of Representatives applauds their leadership in introducing the pending legislation which addresses many of the regulatory challenges faced by providers in implementing HSAs. Read the full comment letters here and here

The DRIVE Health Initiative, a joint project of The ERISA Industry Committee (ERIC) and the Pacific Business Group on Health (PBGH), submitted a public comment letter advocating for the importance of transparency as well as specific gaps in performance information to guide decision-making by consumers and purchasers. Read our statement here.

PBGH issues email statement to CMS: Healthcare Purchasers Support Actions to Provide Patients with Electronic Access to their Complete Health Record


In response to CMS’s Request for Information on the Innovation Center’s new strategic direction, PBGH shared its vision for the health care system and made recommendations to enhance the impact of models tested and expanded under the Innovation Center’s purview. Our specific recommendations are based on lessons learned from our programs and our members’ innovations. Please find our comment letter here.

PBGH, along with 16 consumer and purchaser organizations, signed on to C-P Alliance’s comment letter, expressing significant concerns that the second transition year policies overemphasize clinician flexibility at the cost of performance information for consumers and other stakeholders and other stakeholders. We urge CMS to strengthen program requirements the QPP’s second year program requirements as the proposed rule will not prepare clinicians for the inevitable transition toward a value-driven health care system.

PBGH submitted a letter to the U.S. Congress regarding the “Better Care Reconciliation Act of 2017” (BCRA) discussion draft that was published on June 22. Read PBGH statement .

PBGH, along with 19 consumer and purchaser organizations, signed on to C-P Alliance's comment letter, urging CMS to adopt only high-value measures - that is, those that are meaningful, important, and actionable - in its hospital accountability programs including the Hospital Inpatient Quality Reporting Program (IQR), the Hospital Value-Based Purchasing Program (HVBP), the Hospital-Acquired Condition Reduction Program (HACR), the Hospital Readmissions Reduction Program (HRRP), and the PPS-Exempt Cancer Hospital Quality Reporting Program (PCHQR). We caution CMS against making any changes to these programs to reduce burden without considering the trade-offs in availability of information.

The DRIVE Initiative, a national partnership between PBGH and the ERISA Industry Committee (ERIC) to promote the use of value-based purchasing strategies, submitted testimony before the U.S. House of Representatives Ways & Means Health Subcommittee. The testimony details how Medicare Advantage plans could benefit by adopting value-based health plans designs.

PBGH provided recommendations to the Senate Finance Committee on policies to improve and expand health savings accounts. Drawing lessons from our members’ experience designing and implementing HSA-eligible high-deductible health plans, we urged the Senate Finance Committee to ensure that any changes to HSA policy include: 1) increases in the availability of meaningful performance information that allows comparisons of providers on price and quality, and 2) flexibility for individuals with chronic conditions to access the high-value services they need to manage their health.


PBGH commented on CMS’s proposed rule, Advancing Care Coordination Through Episode Payment Models, which expands CMMI’s mandatory episode-based payment models to AMI, CABG, and hip and femur fractures. In our letter, we recommend CMS use a prospective negotiated rate to calculate payment benchmarks rather than retrospective reconciliation of FFS claims compared to a target price, expand the dashboard of quality measures to reflect a holistic patient experience of care, and encourage the collection and reporting of patient-reported outcomes.

PBGH signed onto a letter along with other consumer organizations and labor groups supporting the proposed Part B demo and CMMI generally.   September 7, 2016

PBGH lent its support to a California Assembly bill which would remove the physician supervision requirement from the practice of Certified Nurse-Midwives (CNM) in California.  Expanded access to CNMs can help improve outcomes and reduce costs of maternity care, particularly in areas with few or no obstetricians.    August 12, 2016

PBGH expressed support for SB 482 which will require all health care practitioners issuing Schedule II, III and IV drugs to consult California's Controlled Substance Utilization Review and Evaluation System (CURES) before prescribing.  The bill is an important step consistent with our members' commitment to combatting prescription drug abuse in California.   August 12, 2016

PBGH commented on the FTC's proposed guidance on labeling for biosimilars, which could provide less costly alternatives for high-cost biologics.  The thrust of our comments was that the label guidelines should not discourage the use of approved biosimilars. August 2, 2016

PBGH sent a letter to CMS recommending that they proceed with the publication of the new Hospital Star Ratings, which provide easy to understand summary ratings of hospital quality for consumers.  July 15, 2016

PBGH commented on the proposed CMS regulations implementing MACRA, which revamps the way physicians are paid under Medicare.  We emphasized the need for standardized measures to compare physician performance and the importance of high standards for "alternative payment models", including downside as well as upside financial risk.  June 27, 2016

Testimony on Claims-based Databases for Policy Development and Evaluation

National Committee on Vital and Health Statistics (NCVHS)
Kristy Thornton, June17, 2016

PBGH comments on newly released proposed rule for implementation of MACRA, April 29, 2016

PBGH comments on CMS Hospital Star Ratings, April 18, 2016

PBGH Statement on Proposed Medicare Part B Drug Pricing Regulations, March 30, 2016

PBGH and C-P Alliance comments on the MACRA draft Measure Development Plan, March 1, 2016

PBGH comments on US Senate Committee on Finance Bipartisan Chronic Care Working Group policy options document, January 26, 2016


PBGH and C-P Alliance comments on CMS’ Request for Information on MACRA Implementation, November 17, 2015

PBGH Statement in Support of the CMS Proposed Revisions to Payment Policies under the Physician Fee Schedule, July 10, 2015

PBGH comments on improving care for Medicare patients with chronic conditions, June, 22, 2015

PBGH submitscomments on excise tax on high cost employer-sponsored health insurance plans to the IRS, May 15, 2015

PBGH letter in support of proposed amendment to California AB 508 - Better healthcare for women and children, April 21, 2015

PBGH letter in support of proposed amendment to California SB 26- CA Health Care Cost and Quality database, April 17, 2015

PBGH Video Commentary and Statement on SGR Replacement Bill, April 14, 2015

PBGH responds to CMMI’s RFI on Advanced Primary Care Model Concepts.  March18, 2015

PBGH Comments on new Medicare ACO Model designed to test whether strong financial incentives for ACOs can encourage improved outcomes at a lower cost.  March 11, 2015

PBGH provides comment on the Medicare Shared Savings Program: Accountable Care Organizations (ACOs) proposed rule
February 6, 2015


PBGH provides comments on key issues of health care transparency legislation to the Senate Finance Committee
August 12, 2014

PBGH Comments on Reference Pricing submitted to the U.S. Department of Labor
August 1, 2014

PBGH Statement on Delay of Meaningful Use Implementation the next step in implementation of the electronic health record (EHR) incentive program.
May 22, 2014

PBGH Statement on the 12-Month “Temporary Fix” to the Medicare Sustainable Growth Rate (SGR)
April 1, 2014

PBGH Statement in Support of the Agreement to Repeal and Replace Medicare Sustainable Growth Rate (SGR)
February 7, 2014



PBGH Comments on the Bi-Partisan Congressional proposal to change the way physicians are paid under Medicare
November 12, 2013

PBGH co-signs a Letter to Congress advocating payment reform in SGR
October 9, 2013

PBGH Statement to CMS on the potential release of physician-specific Medicare data.
September 5, 2013

PBGH Statement to the Energy and Commerce subcommittee on Health on its passage of the SGR Reform Bill
June 26, 2013

David Lansky's Statement to the Senate Commitee on Finance, Health Care Quality: The Path Forward Payment System
June 26, 2013

PBGH Statements to the House Committee on Energy and Commerce Subcommittee on Health, Reforming SGR: Prioritizing Quality in a Modernized Physician Payment System
June 5, 2013

Wall Street Journal publishes PBGH Letter to the Editor, arguing that a recent critique of Medicare's hospital readmissions program overlooked that the program is working.
May 12, 2013

PBGH Executive Director for National Health Policy, Bill Kramer, is quoted in article on CMS's decision to remove hospital-acquired condition (HAC) data from its Hospital Compare website.
May 1, 2013

PBGH Comments on the second draft of the Sustainable Growth Rate (SGR) Repeal and Reform proposal
April 15, 2013

PBGH Statements to House Ways & Means and Energy & Commerce Committees on SGR Replacement and Performance Measures for Physician Payment Programs
February 13, 2013

PBGH Comments on Covered California Model QHP Contract
January 24, 2013

PBGH Input to Request for Information Regarding Health Care Quality for Exchanges
January 17, 2013

PBGH Signs-On to Response for Request for Information regarding Health Care Exchanges
January 14, 2013

PBGH Signs-On to Response to Request for Comments regarding the Meaningful Use of HIT Program
January 14, 2013


Consumer Purchaser Disclosure Comments to Medicare on Physician Fee Schedule
September 4, 2012

Consumer-Purchaser Disclosure Project Comments to Medicare on OPPS/ASC
September 4, 2012

PBGH Imput to the California Health Insurance Exchange on Qualified Health Plans: Strategies to Improve Care, Prevention, Affordability
August 6, 2012

Consumer-Purchaser Disclosure Project Comments on Hospital Inpatient Prospective Payment Systems
June 26, 2012

Consumer-Purchaser Disclosure Project Meaningful Use Comments
May 7, 2012

Consumer-Purchaser Disclosure Project Letter to Secretary Sebelius re: HACs in IQR and HVBP

PBGH Statement to House Ways and Means Committee on Programs that Reward Physicians for Quality and Efficiency
February 21, 2012

PBGH Input to California Health Benefits Exchange on Qualified Health Plans and Delivery Reform
February 15, 2012


PBGH Comment on Exchange Regulations & Qualified Health Plans
October 31, 2011

PBGH Comment on CA Insurance Exchange Vision
September 7, 2011

Input Regarding CMS' Proposed Rule for ACOs, PBGH letter
June 6, 2011

Input Regarding CMS' Proposed Rule for ACOs, PBGH letter, Consumer-Purchaser Disclosure Letter
June 6, 2011

Input Regarding Medicare Hospital Inpatient Value Based Purchasing Proposed Rule
March 7, 2011

How Group Health Plans Should Employ VBID in the Coverage of Preventative Services, a letter to DOL and HHS
February 28, 2011

Input Regarding ACOs and the Medicare Shared Savings Plan
February 14, 2011


Comments on Accountable Care Organizations (ACOs) and the Medicare Shared Saving Program
December 3, 2010

Comments on Implementation of the Physician Compare Website
November 30, 2010

Comments on NCQA Draft Standards for Accountable Care Organizations (ACOs)
November 19, 2010

Comments on the Department of Health and Human Services' National Health Care Quality Strategy and Plan
October 15, 2010

Comments on Planning and Establishment of State-Level Exchanges
October 4, 2010

Comment on Release of Medicare Data for Performance Reporting
September 27, 2010

Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2011 Payment Rates: Comments from National Consumer, Labor, and Employer Organizations
August 31, 2010

Comments on CMS Proposed 2011 Physician Fee Schedule
August 24, 2010

Comments on proposed NCQA Medical Home Standards for 2011
July 2, 2010

Letter in Support of Don Berwick, M.D. Nomination as Administrator of the Centers for Medicare and Medicaid Services (CMS)
June 29, 2010

HHS Interim Final Rule on Implementing a Web Portal
June 4, 2010

Open Letter in Support of Meaningful Use Rule
April 20, 2010

Comments on the Proposed Rule for Incentive Payments to Providers
Background on Meaningful Use
March 15, 2010

Consensus Statement for Delivery Reform in Conference Committee
January 5, 2010


Consensus Statement on Comparative Effectiveness Research
December 2, 2009

Support for Delivery Reform Joint Letter
November 20, 2009

Support of Stand for Quality Comments on H.R. 3590, "Patient Protection and Affordable Care Act"
November 20, 2009

Support of Consumer-Purchaser Disclosure Project Comments on the Centers for Medicare & Medicaid Services Proposed 2010 Physician Fee Schedule
August 31, 2009

Support of Stand for Quality for Assuring Quality Focus in Health Reform
August 19, 2009

PBGH Letter to Congress on the Need for Health Reform to Address Cost Trends for Public and Private Purchasers
August 18, 2009

Joint Letter on Comparative Effectiveness provisions (Section 1401) to the America's Affordable Health Choices Act of 2009 (HR 3200)
August 13, 2009

Creating a Sustainable Path to High Quality Health Care for All Americans
US House Committee on Ways and Means Hearings on Health Reform
Peter V. Lee, June 24, 2009

Support of Consumer-Purchaser Disclosure Project Comments on Meaningful Use of Electronic Health Records (EHR)
Office of the National Coordinator for Health Information Technology
June 21, 2009

"Meaningful Use" of Health Information Technology - View Summary
National Committee on Vital and Health Statistics Executive Subcommittee Hearing.
David Lansky, PhD, April 29, 2009 Audio archive

Testimony on Promoting Delivery System Reform - View Summary
Senate Finance Committee, Roundtable on Reforming America's Health Delivery System. Read additional testimony
Peter V. Lee, April 21, 2009

Testimony on Comparative Effectiveness Research - View Summary
Federal Coordinating Committee for Comparative Effectiveness Research
David Lansky, PhD, April 14, 2009


Comments on Discussion Draft Bill to Establish a Medicare Hospital Value-Based Purchasing Program
Senators Baucus & Grassley, Senate Finance Committee, December 2008

Support of Consumer-Purchaser Disclosure Project Comments on Medicare Value-Based Purchasing for Physician and Other Professional Services
Centers for Medicare & Medicaid Services, December 2008

Promoting Quality and Value in Health Reform
Senate Finance Committee
Peter V. Lee, September 2008

Amicus Brief on behalf of Consumers' Checkbook in a case seeking release of targeted Medicare data for consumers (Checkbook v. HHS, 07-5343 (D.C. Cir.). Notice of Consent
Filed with the Court of Appeals, June 2008

Support of Consumer Purchaser Disclosure Project Comments on Medicare Hospital Payment and Reporting Policies
Centers for Medicare & Medicaid Services, June 2008

Support of Patient Charter for Physician Performance Measurement, Reporting and Tiering Programs
Consumer-Purchaser Disclosure Project, April 2008


Comment to DMHC regarding Proposed Legislation 1300.71
Department of Managed Health Care, October 2007


Public Comment on Medicare Physician Payments
Centers for Medicare & Medicaid Services, August 2006

Public Comment on Physician Specialty Measures
NCQA, August 2006

Public Comment on "National Voluntary Consensus Standards for Symptom Management and End-of-Life Care in Cancer Patients"
NCQA, July 2006

Public Comment on PPO HEDIS Technical Specifications
NCQA, July 2006

Stimulating the Emergence of a 60 Mile Per Gallon American Health Care System
House/Senate Joint Economic Committee
Arnold Milstein, MD, MPH, May 2006

Public Comment to Proposed Changes to Accreditation Standards for 2007
NCQA, April 2006

Public Comment on HEDIS 2007 Measures
NCQA, March 2006


Medicare Physician Payment: How to Build a More Efficient Payment System
Committee on Energy & Commerce, Subcommittee on Health
Peter V. Lee, November 2005

Public Comment on Physician Practice Connection-Cover Letter
Public Comment on Physician Practice Connection-Comments
NCQA, October 2005

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William Kramer
Executive Director for Health Policy

Email:  wkramer@pbgh.org