The AANS and the CNS submitted comments and issued a press release on the Calendar Year (CY) 2025 Medicare Physician Fee Schedule Proposed Rule. The neurosurgical groups expressed concerns about the 2.8% decrease in the CY 2025 conversion factor, resulting primarily from the expiration of the 2024 2.93% bump provided by Congress, plus a positive budget neutrality adjustment of 0.05% triggered by CY 2025 policies. In the letter, the AANS and the CNS urged the Centers for Medicare & Medicaid Services (CMS) to:
- Halt implementation of new initiatives to require an expansion of the use of “transfer of care” modifiers in the surgical global periods and increase the E/M payments in the global periods before taking any other action on the issue;
- Finalize its plan to defer implementation of Medicare Economic Index (MEI) changes to the distribution of relative value unit components (work, practice expense, and professional liability insurance) until all stakeholders can review data from the American Medical Association (AMA) Physician Practice Information (PPI) survey;
- Accept the AMA/Specialty Society Relative Value Scale Update Committee (RUC) recommended values for the new Category I CPT code for MRI-guided focused ultrasound (MRgFUS); and
- Not finalize Osteotomy codes as “potentially misvalued.”
The AANS and the CNS also commented on proposals related to Medicare’s Quality Payment Program (QPP), including:
- Strong opposition to the proposed adoption of the arbitrarily constructed Surgical Care Merit-Based Incentive Payment System (MIPS) Value Pathway (MVP);
- Opposition to the use of MIPS quality measure #59: Back Pain After Lumbar Surgery in MIPS since improving back pain is typically not the primary goal of lumbar fusion surgery; and
- Support for CMS’s commitment to integrating more patient-reported outcome measures (PROMs) into its quality reporting programs and payment and delivery models with a request that CMS achieve a balance between the use of more universally applicable tools, such as PROMIS®, and PROMs that are more appropriate for specific patient populations.
In addition to submitting its own letter and press release, the AANS and the CNS joined several coalition letters. Click here for the Surgical Coalition statement on physician payment, here for the Alliance of Specialty Medicine letter, and here for the Physician Clinical Registry Coalition letter.
For additional details about the proposed rule, click here for a summary from the AMA and here for a CMS fact sheet regarding payment-related proposals. Click here to download a fact sheet regarding QPP proposals and here to download a guide of proposed and modified MVPs for 2025.
