Comment Letter

Neurosurgery Leads Coalition Effort Urging CMS to Increase Global Surgery Codes

  • Reimbursement and Practice Management

Chiquita Brooks-LaSure, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–1770–P
PO Box 8016
Baltimore, MD 21244–8016

Subject: CMS-1770-P; Medicare Program; CY 2023 Payment Policies Under the Physician Payment Schedule and Other Changes to Part B Payment Policies— Global Surgical Packages

Dear Administrator Brooks-LaSure:

On behalf of the undersigned national surgical professional organizations and the members and patients we serve, we are writing to express our ongoing concerns with the Center for Medicare & Medicaid Services’ (CMS) failure to resolve outstanding issues regarding the Medicare
Physician Fee Schedule (PFS) global surgical package. We are particularly frustrated that CMS has refused to appropriately adjust the 10- and 90-day global surgery codes to reflect recent increases in the evaluation and management (E/M) codes — even though the agency has done so
each time the E/M codes were revalued to comply with the Medicare statute’s relativity and specialty payment differential requirements.

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