AANS and CNS Comment on Payment Provisions in Proposed 2016 Medicare Physician Fee Schedule

Re: CMS-1631-P Medicare Program; Payment Policies Under the Physician Fee
Schedule (PFS) and Other Revisions to Part B for CY 2016

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 Physician Fee Schedule (MPFS) Notice of Proposed
Rulemaking (NPRM). We have submitted comments related to the quality issues in a separate comment
letter.

EXECUTIVE SUMMARY

• Professional Liability Insurance (PLI) Relative Value Units (RVUs)
  • The AANS and CNS are concerned about the projected one percent decrease in reimbursement
    for neurosurgery due to changes in the Malpractice RVU calculation. The reported 8 percent
    decrease in neurosurgical malpractice premiums does not reflect the experience of our expert
    panels or the reports from our state and national grassroots organizations.
  • We question the sample size used and the methods by which practicing neurosurgeons were
    identified for inclusion, and there are no descriptions from CMS about how this data was
    gathered.
  • We urge the agency to be certain that data provided on PLI premiums are accurate and provide
    greater transparency regarding the methods for calculating PLI RVUs.

• Proposed Annual Update of PLI RVUs
  • As the specialty with the highest professional liability insurance premiums, neurosurgery supports
    using the most current PLI premium information available. However, updates based on data that
    is only collected every five years only increases the potential that unreliable data will have long-lasting consequences.

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Read full letter here.