Subject: CMS-1717-P Medicare Program: Calendar Year 2020 Hospital Outpatient
Prospective Payment and Ambulatory Surgical Center Payment Systems and
Quality Reporting Programs
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 comment on the above-referenced notice of proposed rulemaking.
EXECUTIVE SUMMARY
Outpatient Prospective Payment System Issues
- Consideration of Removal of Spine Procedure from the Inpatient Only (IPO) List. The AANS and the CNS support the removal of CPT codes 63265-63268 (laminectomy for excision or evacuation of intraspinal lesion other than neoplasm, extradural) and CPT codes 22633 and 22634 (combined posterior or posterolateral technique with posterior interbody technique including laminectomy and/ or discectomy sufficient to prepare interspace (other than for decompression), single interspace and segment; lumbar) from the IPO. However, we emphasize the importance of patient selection in determining the site of service. Inpatient admission should remain an option for patients who require that level of care.
- Magnetic Resonance-guided Focused Ultrasound (MRgFUS) for Essential Tremor (ET). The AANS and the CNS urge CMS to reverse its decision from last year to reassign MRgFUS to a lower-paying APC and restore appropriate reimbursement for this promising new technology.
- Pass-through Status for VNS for Treatment-Resistant Depression (TRD). The AANS and the CNS support pass-through designation for VNS for TRD.
- Expedited “Pass-through” eligibility for Breakthrough Devices. We commend the agency for efforts to expedite the process for pass-through payment eligibility for breakthrough devices.
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