The Alliance submitted comments in response to CMS' proposal to repeal the Medicare Coverage of Innovative Technology (MCIT) and the Definition of “Reasonable and Necessary” rules. In its notice of repeal, CMS had solicited stakeholder input prior to developing a new, separate policy addressing expedited coverage pathways for innovative technologies. The Alliance urged CMS to quickly move forward in issuing a new policy and provided a detailed list of issues and questions to consider as that proposed rule is developed. Comments also reiterated Alliance concern with the "reasonable and necessary" provisions of the original MCIT rule and discouraged inclusion of such provisions in the new rule. 

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