Quality Improvement and Patient Safety

The AANS and CNS are committed to quality improvement and supports innovative efforts to provide high quality, cost-effective care to patients. While Congress has taken the first steps towards implementing quality improvement programs, the current Physician Quality Reporting System (PQRS — formerly PQRI) needs to be drastically reworked to better incorporate a system for clinical data collection and reporting. A "one-size-fits-all" approach will not result in better patient outcomes. The AANS and CNS support a pay-for-participation system under which data regarding physician quality are collected in a nonpunitive environment and analyzed using accurate risk‐adjustment mechanisms; public reporting of data only occurs at the aggregate level and not at the individual level; and physicians receive performance feedback continually and in a timely manner. Organized neurosurgery will continue to push the message that Congress should rescind the PQRS penalties, reconsider the value‐based payment modifier and streamline the federal quality improvement programs created by the Affordable Care Act (ACA).

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Comment Letter

AANS and CNS Comment on Medicare Hospital Payment Proposed Rule

Last updated: June 11, 2024
Ms. Chiquita Brooks-LaSure, AdministratorCenters for Medicare & Medicaid ServicesU.S. Department of Health and Human ServicesATTN: CMS-1808-PP.O. Box 8013 Baltimore, MD 21244-1850 Submitted electronically via www.regulations.gov Subject: CMS-1808-P Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes Dear Administrator Brooks-LaSure, On behalf […]
  • Quality Improvement and Patient Safety
  • Reimbursement and Practice Management
Washington E-Newsletter

AANS and CNS Voice Concerns about MIPS Total Per Capita Cost Measure

Last updated: June 25, 2024
The AANS and the CNS recently submitted comments to the Centers for Medicare & Medicaid Services’ contractor, Acumen, LLC, regarding its re-evaluation of the Total Per Capita Cost (TPCC) measure currently in use under the Merit-based Incentive Payment System (MIPS). The TPCC measure evaluates the overall cost of care in both Medicare Part A and […]
  • Quality Improvement and Patient Safety
Washington E-Newsletter

Neurosurgery Urges CMS to Reduce Burdens Associated with APM Participation

Last updated: June 7, 2024
On April 10, the AANS and the CNS joined dozens of national physician organizations and more than 100 Accountable Care Organizations (ACOs), health systems, hospitals, clinics and practices from across the country in opposing two recently finalized policies in the 2024 Medicare Physician Fee Schedule. These policies pertain to certified electronic health record technology utilization […]
  • Quality Improvement and Patient Safety
Washington E-Newsletter

CMS Releases 2022 QPP Participation and Performance Data

Last updated: June 7, 2024
Recently, the Centers for Medicare & Medicaid Services (CMS) released national participation and performance data for the Quality Payment Program’s (QPP) 2022 performance year, including data related to the Merit-based Incentive Payment System (MIPS) and alternative payment model (APM) participation. Notable findings include: Additional information about 2022 participation/performance data and 2024 payment adjustments is available […]
  • Quality Improvement and Patient Safety
Washington E-Newsletter

2024 MIPS Exception Application Now Available

Last updated: June 7, 2024
The Centers for Medicare & Medicaid Services (CMS) recently released its 2024 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable (EUC) Circumstances exception application, which can be submitted for purposes of the 2024 Merit-based Incentive Payment System (MIPS) through Dec. 31. Note that CMS will not accept MIPS EUC exception applications due to COVID-19 for […]
  • Quality Improvement and Patient Safety
Comment Letter

AANS and CNS Comment on Total Cost of Care Measure

Last updated: June 10, 2024
Acumen, LLC500 Airport Blvd., Suite 100Burlingame, CA 94010 Submitted via: macra-cost-measures-info@acumenllc.com SUBJECT: 2024 Total Per Capita Cost Measure Re-evaluation To whom it concerns: On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate the opportunity to provide […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Urges CMS to Reduce Burdens Associated with APM Participation

Last updated: June 10, 2024
The Honorable Chiquita Brooks-LaSureAdministratorCenters for Medicare & Medicaid ServicesU.S. Department of Health and Human ServicesHubert H. Humphrey Building, Room 445–G 200Independence Avenue, SWWashington, DC 20201 Dear Administrator Brooks-LaSure: The undersigned, which include dozens of national physician organizations representing hundreds of thousands of physicians, as well as over one hundred Accountable Care Organizations (ACOs), health systems, […]
  • Quality Improvement and Patient Safety
Washington E-Newsletter

AANS and CNS Comment on Cost Measures for Movement Disorders

Last updated: May 9, 2024
On Feb. 28, the AANS and the CNS commented on proposed cost measures for movement disorders. Jason M. Schwalb, MD, FAANS — a stereotactic and functional neurosurgeon specializing in surgery for neurological disorders that impact movement — serves on the measure development workgroup organized by Acumen, LLC, the Centers for Medicare & Medicaid Services contractor […]
  • Quality Improvement and Patient Safety
Washington E-Newsletter

CMS Extends MIPS 2023 Data Submission Deadline Through April 15

Last updated: May 9, 2024
The Centers for Medicare & Medicaid (CMS) announced it is extending the deadline for eligible clinicians to submit their 2023 Merit-Based Incentive Payment System (MIPS) performance data in response to the Change Healthcare cybersecurity attack. The 2023 MIPS data submission window opened on January 2 and was initially scheduled to close on April 1. Clinicians […]
  • Quality Improvement and Patient Safety
Comment Letter

AANS and CNS Comment on Cost Measures for Movement Disorders

Last updated: June 10, 2024
Acumen, LLC500 Airport Blvd. Suite 365Burlingame, CA 94010 Submitted via macra-clinical-committee-support@acumenllc.com Subject: 2024 Cost Measure Field Testing-Wave 6 Movement Disorders Cost Measure To whom it may concern: On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Urges VA to Respect State Scope of Practice Laws

Last updated: June 10, 2024
The Honorable Denis McDonoughSecretaryU.S. Department of Veterans Affairs810 Vermont Avenue NWWashington, DC 20420 Dear Secretary McDonough: The undersigned medical societies are writing to convey our ongoing concerns with the Department of Veterans Affairs (VA) effort to develop National Standards of Practice (NSP) through the Federal Supremacy Project. We urge the VA to address flaws in […]
  • Quality Improvement and Patient Safety
Comment Letter

AANS and CNS Oppose Development of Flawed Quality Measures

Last updated: June 10, 2024
Centers for Medicare & Medicaid Services7500 Security BoulevardBaltimore MD 21244 Submitted electronically to PIMMSMVPSupport@gdit.com Subject: Draft 2025 MVP Candidate Feedback To whom it concerns: On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate the opportunity to […]
  • Quality Improvement and Patient Safety
Comment Letter

AANS and CNS Submit Comments re Information Blocking and Data Registries

Last updated: June 10, 2024
ELECTRONICALLY SUBMITTED The Honorable Chiquita Brooks-LaSureAdministratorCenters for Medicare and Medicaid ServicesU.S. Department of Health and Human Services7500 Security BoulevardBaltimore, Maryland 21244 Micky Tripathi, Ph.D.National Coordinator for Health Information TechnologyOffice of the National Coordinator for Health Information TechnologyU.S. Department of Health and Human Services330 C Street SW, Floor 7Washington, D.C. 20201 Re: Physician Clinical Registry Coalition’s […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Joins Coalition in Commenting on Development of Episode-Based Payment Models

Last updated: June 10, 2024
VIA ELECTRONIC MAIL The Honorable Chiquita Brooks-LaSureAdministratorCenters for Medicare and Medicaid ServicesU.S. Department of Health and Human ServicesAttention: CMS-5540-NC7500 Security Boulevard, Mail Stop C4-26-05Baltimore, MD 21244-1850 Re: File Code CMS-5540-NC: Request for Information; Episode-Based Payment Model Dear Administrator Brooks-LaSure: The undersigned members of the Physician Clinical Registry Coalition (“Coalition”) appreciate the opportunity to comment on […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Joins Registry Coalition in Commenting on Medicare Quality Payment Program Proposals

Last updated: June 10, 2024
Submitted Electronically via www.regulations.gov The Honorable Chiquita Brooks-LaSureAdministratorCenters for Medicare and Medicaid ServicesDepartment of Health and Human ServicesAttention: CMS–1784–PMail Stop C4-26-057500 Security BoulevardBaltimore, MD 21244-1850 RE: Physician Clinical Registry Coalition’s Comments on the Proposed 2024 Updates to the Quality Payment Program (CMS-1784-P) Dear Administrator Brooks-LaSure: The undersigned members of the Physician Clinical Registry Coalition (the […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Comments on HIT Proposed Rule

Last updated: June 10, 2024
Micky Tripathi, PhD, MPPNational CoordinatorOffice of the National Coordinator for Health Information TechnologyDepartment of Health and Human ServicesAttention: HTI-1 Proposed Rule (RIN 0955-AA03)Mary E. Switzer Building330 C. St S.W., 7th FloorWashington, D.C. 20024 RE: Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing (HTI-1) Proposed Rule Dear National Coordinator Tripathi, The […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Comments on Episode-Based Payment Models

Last updated: June 10, 2024
Chiquita Brooks-LaSureAdministratorCenters for Medicare & Medicaid ServicesU.S. Department of Health and Human Services7500 Security BoulevardBaltimore, Maryland 21244 Submitted electronically via www.regulations.gov Subject: Request for Information; Episode-Based Payment Model (CMS-5540-NC) Dear Administrator Brooks-LaSure, On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Comments on Integrating Specialty Care in Population-Based Models

Last updated: June 10, 2024
Miranda Lynch-SmithDeputy Assistance Secretary, Office of Human Services Policy (HSP)Assistant Secretary for Planning and Evaluation, Room 415FU.S. Department of Health and Human Services200 Independence Avenue, SWWashington, DC 20201Submitted electronically via: PTAC@HHS.gov RE: Improving Care Delivery and Integrating Specialty Care in Population-Based Models Request for Input (RFI) Dear Ms. Lynch-Smith, The Alliance of Specialty Medicine (the […]
  • Quality Improvement and Patient Safety
Comment Letter

AANS and CNS Urge CMS to Improve Medicare Quality Payment Program

Last updated: June 10, 2024
The Honorable Chiquita Brooks-LaSureAdministratorCenters for Medicare & Medicaid ServicesU.S. Department of Health and Human ServicesHubert H. Humphrey Building, Room 445–G 200Independence Avenue, SWWashington, DC 20201 Dear Administrator Brooks-LaSure: On behalf of the undersigned organizations representing physicians across the country, we agree with the Centers for Medicare & Medicaid Services’ (CMS) aims in the Merit-based Incentive […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Submits Comments to Congress on Medicare Payment and Quality Program Improvements

Last updated: June 12, 2024
Submitted via: macra.rfi@mail.house.gov Subject: Request for Information (RFI) on the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 Dear Representatives Bera, Bucshon, Schrier, Burgess, Blumenauer, Wenstrup, Schneider and Miller-Meeks: On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS), representing more than 4,000 practicing neurosurgeons in the United […]
  • Quality Improvement and Patient Safety
  • Reimbursement and Practice Management
Comment Letter

AANS and CNS Comment on 2023 Medicare OPPS and ASC Proposed Rule

Last updated: June 26, 2024
Ms. Chiquita Brooks-LaSure, AdministratorCenters for Medicare & Medicaid ServicesU.S. Department of Health and Human ServicesATTN: CMS-1751-PP.O. Box 8013 Baltimore, MD 21244-1850 Submitted electronically via www.regulations.gov Subject: CMS-1772-P Medicare Program: Calendar Year (CY) 2023 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Organ Acquisition; Rural Emergency Hospitals: Payment Policies, Conditions […]
  • Quality Improvement and Patient Safety
  • Reimbursement and Practice Management
Comment Letter

Neurosurgery Joins the Alliance in Comments on 2023 Medicare Physician Fee Schedule Proposed Rule

Last updated: June 26, 2024
Ms. Chiquita Brooks-LaSure, AdministratorCenters for Medicare & Medicaid ServicesDepartment of Health and Human ServicesAttention: CMS-1770-PP.O. Box 8013Baltimore, MD 21244-8016 Submitted electronically via www.regulations.gov RE: Medicare and Medicaid Programs; CY 2023 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicare and Medicaid Provider Enrollment […]
  • Quality Improvement and Patient Safety
  • Reimbursement and Practice Management
Comment Letter

AANS and CNS Comment on 2023 Medicare Physician Fee Schedule Proposed Rule

Last updated: June 26, 2024
Ms. Chiquita Brooks-LaSure, AdministratorCenters for Medicare & Medicaid ServicesU.S. Department of Health and Human ServicesATTN: CMS-1751-PP.O. Box 8013 Baltimore, MD 21244-1850 Submitted electronically via www.regulations.gov Subject: CMS-1770-P Medicare Program; CY 2023 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; […]
  • Quality Improvement and Patient Safety
Comment Letter

Neurosurgery Comments on Quality Provisions of 2023 Proposed Medicare Fee Schedule

Last updated: June 26, 2024
Submitted Electronically via www.regulations.gov The Honorable Chiquita Brooks-LaSureAdministratorCenters for Medicare and Medicaid ServicesDepartment of Health and Human ServicesAttention: CMS-1770-PMail Stop C4-26-057500 Security BoulevardBaltimore, MD 21244-1850 RE: Physician Clinical Registry Coalition’s Comments on the Proposed 2023 Updates to the Quality Payment Program (CMS-1770-P) Dear Administrator Brooks-LaSure: The undersigned members of the Physician Clinical Registry Coalition (the […]
  • Quality Improvement and Patient Safety