December 31, 2019
Seema Verma, MPH, Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G
200 Independence Avenue, SW
Washington, DC 20201
Submitted electronically via www.regulations.gov
Subject: CMS-1715-F Medicare Program; Revisions to Payment Policies Under the
Physician Fee Schedule (PFS) and Other Revisions to Part B for Calendar Year
(CY) 2020
Dear Administrator Verma:
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 our feedback on the evaluation and management (E/M)
office/outpatient visit provisions open to comment in the above-referenced final rule.
Failure to Incorporate Increased E/M Values in Global Surgical Services
The AANS and the CNS strongly object to the continued failure of CMS to incorporate the CY 2021
increases in the evaluation and management (E/M) office visit codes into the 10- and 90-day global
surgical codes. Organized medicine has spoken with a unified voice on this topic and it is difficult for us
to understand the rationale for not incorporating those increases. We urge you to review comments in
previous letters from members of Congress, the AANS, the CNS, the American Medical Association
(AMA), the American College of Surgeons (ACS) and many other specialty societies asking the agency
to reconsider this decision and to adjust the global codes to reflect the AMA/Specialty Society Relative
Value Scale (RVS) Update Committee (RUC)-recommended increases in office visit work. We are
deeply concerned that CMS has failed to heed the recommendations of virtually all medical specialties
and the precedents set by the agency in ignoring the law and long-time practice regarding the Medicare
PFS.
Read full letter here
