Comment Letter

AANS and CNS Comment on 2023 Medicare Physician Fee Schedule Proposed Rule

  • Quality Improvement and Patient Safety

Ms. Chiquita Brooks-LaSure, Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
ATTN: CMS-1751-P
P.O. Box 8013 Baltimore, MD 21244-1850

Submitted electronically via

Subject: CMS-1770-P Medicare Program; CY 2023 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; Provider and Supplier Prepayment and Post-Payment Medical Review Requirements.

Dear Administrator Brooks-LaSure:

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 payment and quality provisions of the above referenced notice of proposed rulemaking.



Conversion Factor

The AANS and the CNS are concerned about the overall decrease in the Calendar Year (CY) 2023
conversion factor. We urge CMS to take all possible actions to provide a positive update to the Medicare
conversion factor in 2023.

Click here to read the full AANS and CNS Comment on 2023 Medicare Physician Fee Schedule Proposed Rule.