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 8013
Baltimore, MD 21244-8013

RE: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals (IPPS) and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year (FY) 2027 Rates; Requirements for Quality Programs; and Other Policy Changes [CMS-1849-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) fiscal year (FY) 2027 Hospital Inpatient Prospective Payment Systems (IPPS) proposed rule published in the Federal Register on April 14, 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 proposal to establish a new family of MS-DRGs for extensive and complex spinal fusion procedures, as well as the Agency’s Request for Information regarding physician-owned hospitals (POHs) and participation in the Transforming Episode Accountability Model (TEAM). Collectively, these proposals present important opportunities to improve the accuracy of Medicare payment policy, strengthen the evaluation of value-based care models, and ensure that reimbursement and accountability frameworks appropriately reflect clinical complexity, resource utilization, and patient outcomes.

Click here to view the full Comment Letter on the FY 2027 IPPS and LTCH PPS Proposed Rule