VIA ELECTRONIC TRANSMISSION

The Honorable Mehmet Oz, MD, MBA
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
P.O. Box 8010
Baltimore, MD 21244–8010

RE: Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical CenterPayment Systems; and Quality Reporting Programs; including the Hospital Outpatient Quality Reporting Program and Ambulatory Surgical Center Quality Program; Request for Information on Strengthening the Standardization and Comparability of Hospital Price Transparency (HPT) Data; Prior Authorization; Accrediting Organization (AO) Deeming for Emergency Medical Treatment and Labor Act (EMTALA); and Notices of Closure of Teaching Hospitals and Opportunities To Apply for Available Slots [CMS-1850-P]

Dear Administrator Oz:

On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons nationwide, we appreciate the opportunity to submit comments to the Centers for Medicare & Medicaid Services’ (CMS) calendar year (CY) 2027 Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems and Quality Reporting Programs proposed rule published in the Federal Register on July 7, 2026.

The proposed rule addresses several issues of significant importance to neurosurgical patients and providers. In particular, the AANS and CNS comment on CMS’s proposed phase-out of the Inpatient Only (IPO) list, prior authorization requirements for cervical fusion with disc removal and implanted spinal neurostimulators, and proposed changes to hospital outpatient and ASC quality measurement. Collectively, these proposals present important opportunities to ensure that Medicare payment and quality policies appropriately reflect clinical complexity and judgment, patient outcomes, and resource requirements.

Click here to view the full Comments on CY 2027 Medicare OPPS and ASC Proposed Rule (CMS-1850-P)