Comment Letter

AANS and CNS Comment on Medicare Hospital Payment Proposed Rule

  • Quality Improvement and Patient Safety
  • Reimbursement and Practice Management

Ms. Chiquita Brooks-LaSure, Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
ATTN: CMS-1808-P
P.O. Box 8013 Baltimore, MD 21244-1850

Submitted electronically via

Subject: CMS-1808-P Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes

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 provisions of the above-referenced notice of proposed rulemaking.


The AANS and the CNS note that CMS has proposed to change the spinal fusion Medicare Severity-Diagnosis Related Groups (MS-DRGs) to better account for what CMS has concluded is the biggest driver of cost differentials: whether the case is single or multiple levels. While we appreciate and share the agency’s desire to reflect the hospital facility costs as accurately as possible, we need more information about the potential impact of the new DRG designations and an opportunity to study the changes further. We request that additional insight and rationale be provided for the MS-DRGs that CMS proposes to change. We also would like to understand why the agency did not incorporate six MS-DRGs into the analysis. Finally, we would like to learn why CMS excluded several MS-DRGs from any proposed changes at all, instead opting to maintain the current structure.

Click here to view the full AANS and CNS Comment on Medicare Hospital Payment Proposed Rule.