Andy Slavitt, Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201
Subject: Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals
and the Long-Term Care Hospital Prospective Payment System Policy Changes
and FY 2016 Rates Proposed Rule
Dear Mr. Slavitt,
On behalf of more than 4,000 practicing neurosurgeons in the United States, the American Association of
Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS) appreciate the
opportunity to comment on the above referenced CMS hospital inpatient prospective payment system
proposed rule.
PAYMENT PROVISIONS
Add-on Payments for New Services and Technologies
Responsive Neurostimulator (RNS) System
The AANS and CNS are pleased to see that CMS proposes to grant new technology add-on payment for
the responsive neurostimulator (RNS) system. The technology represents a substantial clinical
improvement for patients who are medically refractive or not candidates for surgery. We presented these
views at the Food and Drug Administration’s (FDA) Neurological Devices Advisory Panel on February 22,
2013, and in our comments on the IPPS proposed rule for the last two years. A significant number of
epilepsy patients, possibly over a third of these individuals, will not find adequate relief from medications.
Some of these patients may be helped by traditional surgery, but that carries risk and discomfort to the
patient, as with any surgery. The likelihood that people with intractable epilepsy will be helped by a
traditional surgery is perhaps less than ten percent, leaving a large portion of patients with either
medically or surgically untreatable epilepsy. We believe for those patients RNS offers substantial clinical
improvement, and we support CMS’ plan to grant a new technology add-on payment for RNS.
QUALITY PROVISIONS
Hospital Inpatient Quality Reporting (IQR) Program
Lumbar Spine Fusion/Re-Fusion Clinical Episode-Based Payment measure
CMS proposes to add eight new measures to the Hospital IQR Program starting with the FY 2018
payment determination and subsequent years, including a claims-based Lumbar Spine Fusion/Re-Fusion
Clinical Episode-Based Payment measure.
…
Read full letter here
