Subject: CMS-1715-P Medicare Program; Revisions to Payment Policies Under the
Physician Fee Schedule (PFS) and Other Revisions to Part B for CY 2020;
Medicare Shared Savings Program Requirements; Quality Payment Program; and
Medicaid Promoting Interoperability Program
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.
EXECUTIVE SUMMARY
Evaluation and Management Office/Outpatient Visit Valuation and Global Surgical Codes
- The AANS and the CNS strongly object to the failure of CMS to incorporate proposed increases in the evaluation and management (E/M) office visit codes in the 10- and 90-day global surgical services. We urge you to review the letter from AANS, the CNS and more than 50 other specialty societies representing the supermajority of physicians in the house of medicine 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.
- The AANS and the CNS note that CMS has disregarded the original intent of the agency and the CPT/RUC Workgroup on E/M Coding proposals, which was to reduce administrative and documentation burden for physicians. The CPT/RUC Workgroup specifically stated that its intention was to maintain relativity and not to redistribute payment between specialties. CMS’ failure to increase the global surgical payments to account for the E/M office/outpatient visits ignores this intent, destroys the relativity of the entire physician fee schedule and pays physicians of different specialties different amounts for the same work. The AANS and the CNS urge CMS to increase the global surgical services to reflect increases in E/M office/outpatient visit codes. This will more fairly reduce the redistribution in payment.
Read full letter here
