On Sept. 6, the AANS and the CNS submitted comments on the Calendar Year (CY) 2024 Medicare Physician Fee Schedule Proposed Rule. The neurosurgical groups expressed concerns about the 3.5% decrease in the CY 2024 conversion factor, primarily stemming from a new office visit add-on code (G2211) for complex services. In their letter, the AANS and the CNS urged the Centers for Medicare & Medicaid Services (CMS) to:
- Halt implementation of the G2211 add-on code;
- Adjust the 10- and 90-day global codes to reflect increases in the value of post-operative evaluation and management services; and
- Accept the American Medical Association/Specialty Society Relative Value Scale Update Committee-recommended values for the total disc arthroplasty code (CPT code 22860).
The AANS and the CNS also commented on Medicare’s Quality Payment Program issues. Among other things, the letter:
- Objected to the new Merit-Based Incentive Payment System Value Pathways framework;
- Requested that CMS maintain measure #128: Body Mass Index Screening so that it is available to specialists who otherwise have access to very few relevant measures; and
- Registered concerns about the flawed approach to cost measurement and the inclusion of surgeons in the newly developed Low Back Pain episode-based cost measure, which is aimed at evaluating non-operative, chronic care.
Responding to neurosurgery’s ongoing advocacy, CMS proposed suspending the implementation of the Appropriate Use Criteria for Advanced Diagnostic Imaging Program due to unsurmountable operational challenges and a reassessment of the program’s utility.
Besides their letter, the AANS and the CNS joined several coalition letters. Click here for a surgical coalition letter opposing the G2211 add-on code, here for the Alliance of Specialty Medicine letter and here for the Physician Clinical Registry Coalition letter.
For additional details about the proposed rule, click here for a summary of provisions of interest to neurosurgery and here for a CMS fact sheet.
