SUBJECT: Medicare Program; CY 2018 Updates to the Quality Payment Program
Proposed Rule (CMS-5522-P)
Dear Administrator Verma:
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 on proposed updates to the Quality Payment Program
(QPP) for 2018. The AANS and CNS recognize that implementing the Medicare Access and CHIP
Reauthorization Act (MACRA) is a challenging task. We greatly appreciate that this Administration is
taking an incremental approach that focuses on ways to drive improvements in patient outcomes in the
least burdensome manner possible, that recognizes diversity among clinician practices in regards to
patient populations and experience with quality measurement, and that appreciates current limitations
related to system capabilities that are often outside of the clinician’s direct control. Still, we continue to
have overarching concerns about the complexity of this new program and its failure to convert the
disjointed and duplicative nature of legacy quality reporting programs into a more streamlined structure.
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