Comment Letter

Neurosurgery Urges CMS to Eliminate Unnecessary Add-on Code Driving Medicare Pay Cuts

  • Reimbursement and Practice Management

Chiquita Brooks-LaSure, MPP
Administrator 
Centers for Medicare & Medicaid Services  
Attention: CMS-1784-P
P.O. Box 8016
Baltimore, MD 21244-8016

RE: Medicare and Medicaid Programs; CY 2024 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Advantage; Medicare and Medicaid Provider and Supplier Enrollment Policies; and Basic Health Program.

Dear Administrator Brooks-LaSure:

On behalf of the undersigned 19 surgical organizations, we write to strongly oppose the implementation of Healthcare Common Procedure Coding Systems (HCPCS) add-on code G2211 as set forth in the Centers for Medicare & Medicaid Services’ (CMS or the Agency) calendar year (CY) 2024 Medicare Physician Fee Schedule (PFS) proposed rule. Our groups have expressed our opposition for years because this code will harm surgeons and, in turn, surgical patients. A summary of our views is as follows:

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