On Aug. 31, the AANS and the CNS submitted detailed comments to the Centers for Medicare & Medicaid Services (CMS) regarding the 2023 proposed Medicare Physician Fee Schedule rule. In the letter, the neurosurgical societies offered the following recommendations regarding the payment provisions urging CMS to:
- Delay any change in the Medicare Economic Index until additional practice cost data collection work is completed;
- Incorporate the increased evaluation and management code values into the global surgery codes; and
- Accept the American Medical Association/Specialty Society RVS Update Committee values for eight spine codes.
The AANS and the CNS also supported the proposal to extend flexible telehealth policies.
Regarding the Quality Payment Program, the societies urged CMS to:
- Ensure a diverse inventory of measures that reflect specialty care in the Merit-Based Incentive Payment System (MIPS);
- Refrain from lumping fusions in with discectomies/decompressions for the MIPS Back Pain After Lumbar Fusion and Leg Pain After Lumbar Fusion quality measures; and
- Encourage Congress to make technical updates to the Medicare Access and CHIP Reauthorization Act to extend the expiring 5% incentive payment for qualifying participants (QPs) in Advanced Alternative Payment Models and maintain the current QP eligibility threshold levels.
The AANS and the CNS also joined the Alliance in sending a letter recommending that CMS take steps to prevent the planned Medicare payment cuts and establish policies that expand access to telehealth and virtual care services. In addition, the AANS and the CNS joined the Physician Clinical Registry Coalition in a letter expressing concerns about policies that hinder the use of registries in MIPS.
A summary of issues of interest to neurosurgery in the proposed rule is available here.