AR

**FULL COMMENT ATTACHED** Thank you for the opportunity to comment on the emergency review of the collection of information related to the pre- and post-payment review of Medicare claims by Medicare contractors. On behalf of the 5,000 cardiologists in private practice and within integrated organizations across the country that we represent, the Cardiology Advocacy Alliance (CAA) submits the following observations about the proposed CMS-10417 information collection. In response to this proposed expanded information request by the Centers for Medicare & Medicaid Services (CMS), CAA is disappointed by the clear increase in cost and waste to private practice medicine to respond to contractor documentation requests. This unfunded mandate is further exacerbated by the simple fact that the seven days afforded by this emergency public information collection review is simply not adequate for appropriate and legally required public comment. In light of these concerns and others expressed below, the CAA recommends that CMS delay the implementation of this proposed information request until the following occurs: (1) a renewed public information collection review request of no fewer than 30 business days for appropriate public comment; (2) the final Attachments Rule is published by CMS; (3) a public opportunity to review the contractor request process and materials with no fewer than 30 business days for comment; and (4) a system is developed, tested and deployed to coordinate the request activities of various Medicare contractors in California, Florida, Illinois, Louisiana, Michigan, Missouri, New York, North Carolina, Ohio, Pennsylvania and Texas.