Andy Slavitt, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1633-P
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201
Re: CMS-1633-P Medicare Program; Hospital Outpatient Prospective Payment and
Ambulatory Surgical Center Payment Systems for CY 2016; Proposed Rule
Dear Mr. Slavitt:
On behalf of 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 payment provisions of the above referenced Centers for Medicare and
Medicaid Services’ (CMS) 2016 Medicare Hospital Outpatient Prospective Payment System (OPPS)
and Ambulatory Surgical Center (ASC) Payment Systems for 2016. AANS and CNS believe that the
decision for site of service in cases where a procedure may typically be performed safely in multiple
settings, should remain with the operating surgeon in consultation with the patient. As such, we offer
the following comments.
Proposed Changes to the Inpatient Only List
AANS and CNS support the CMS proposal to remove the following four spine procedures from the
Inpatient Only List:
- CPT Code 20936, Autograft for spine surgery only (includes harvesting the graft); local (eg,
ribs, spinous process, or laminar fragments) obtained from the same incision; - CPT Code 20937 Autograft for spine surgery only (includes harvesting the graft); morselized
through separate skin or fascial incision) - CPT Code 20938 Autograft for spine surgery only (includes harvesting the graft); structural,
bicortical or tricotical (through separate skin or fascial incision) - CPT Code 22552 Arthrodesis, anterior interbody, including disc space preparation,
discectomy, osteophytectomy and decompression of spinal cord and/or nerve roots; cervical
below C2, each additional interspace;
…
Read full letter here.
