Subject: CMS-1736-P Medicare Program: Calendar Year 2020 Hospital Outpatient
Prospective Payment and Ambulatory Surgical Center Payment Systems and
Quality Reporting Programs; Addition of New Categories for Hospital Outpatient
Department Prior Authorization Process; Clinical Laboratory Fee Schedule:
Potential Revisions to the Laboratory Date of Service Policy; Proposed Overall
Hospital Quality Star Rating Methodology for Public Release in CY 2021 and
Subsequent Years; and Physician-owned Hospitals
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.
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