Subject: CMS-1734-P Medicare Program; Revisions to Payment Policies Under the
Physician Fee Schedule (PFS) and Other Revisions to Part B for CY 2021;
Medicare Shared Savings Program Requirements; Medicaid Promoting
Interoperability Program Requirements for Eligible Professionals; Quality
Payment Program; Coverage of Opioid Use Disorder Services Furnished by
Opioid Treatment Programs; Medicare Enrollment of Opioid Treatment
Programs; Electronic Prescribing for Controlled Substances for a Covered
Part D Drug Under a Prescription Drug Plan or an MA-PD Plan; Payment for
Office/Outpatient Evaluation and Management Services; Hospital IQR
Program; Establish New Code Categories; and Medicare Diabetes Prevention
Program (MDPP) Expanded Model Emergency Policy
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 payment provisions of the above-referenced notice of
proposed rulemaking. Neurosurgery’s comments on the quality-related aspects of the proposed rule
are included in a separate letter.
Read full letter here
