Comment Letter

AANS and CNS Comment on Total Cost of Care Measure

  • Quality Improvement and Patient Safety

Acumen, LLC
500 Airport Blvd., Suite 100
Burlingame, CA 94010

Submitted via:

SUBJECT: 2024 Total Per Capita Cost Measure Re-evaluation

To whom it concerns:

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 provide feedback in response to Acumen’s effort to re-evaluate the Total Per Capita Cost (TPCC) measure currently in use under the Merit-based Incentive Payment System

Although neurosurgeons, as a specialty, are excluded from the TPCC measure, we are opposed to any measure that creates perverse incentives to undertreat patients. The TPCC is fundamentally flawed because it not only holds physician accountable for costs outside of their reasonable control but is based exclusively on administrative claims data and inadequate risk adjustment methodologies that fail to assess the appropriateness of surgery accurately. As a result, primary care physicians may avoid or delay referring a patient to a surgeon, even when such care is indicated, for fear of getting penalized for the high cost of surgical services. For any given spine surgery, there is tremendous variation in cost. While some might be warranted and some might not, this is impossible to discern from claims data. The TPCC measure inaccurately assumes that surgery is a uniform treatment.

Click here to read the full AANS and CNS Comment on Total Cost of Care Measure.