Subject: CMS-3372-P Medicare Program: Medicare Coverage of Innovative Technology
(MCIT) and Definition of “Reasonable and Necessary”
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 above-referenced notice of proposed rulemaking.
Medicare Coverage of Innovative Technology (MCIT) Pathway
Neurosurgeons are at the cutting-edge of advances in treating diseases and disorders of the brain, spine
and peripheral nerves — including stroke, back pain, traumatic brain injury, epilepsy, Parkinson’s
disease and tumors. Drugs, devices and biologics regulated by the Food and Drug Administration (FDA)
are essential elements of neurosurgical treatments. As such, access to breakthrough technology is
particularly important for our specialty and the patients we serve. We, therefore, support Medicare
coverage for breakthrough technology but urge the agency at the same time to safeguard high-quality
and real-world evidence development for the technologies.
Read full letter here
