Re: Medicare Program; Revisions to Payment Policies under the Physician Fee
Schedule, Clinical Laboratory Fee Schedule & Other Revisions to Part B for CY
2015; CMS-1612-P
Dear Ms. Tavenner:
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) 2015 Medicare Physician Fee Schedule (MPFS) Notice of Proposed
Rulemaking (NPRM). We have submitted comments related to the quality and Open Payment
proposals in separate comment letters.
Summary of Comments
- Resource-Based Relative Value Units (RBRVS) for Practice Expense (PE)
− The AANS and CNS agree with the CMS proposal regarding Stereotactic Radiosurgery (SRS)
treatment delivery and believe CPT Codes 77372 and 77373 should be used by CMS for
these services. - Validating RVUs of Potentially Misvalued Codes
− The AANS and CNS continue to have a number of concerns regarding contracts with the
Urban Institute and the RAND Corporation undertaken by CMS to gather data to review. We
urge transparency and adequate public comment in this process.
− We do not agree with the need to review the work of the Neurostimulator Implantation (CPT
codes 64553 and 64555) in addition to the Practice Expense (PE), but understand that the
codes have been referred to the RUC. The AANS and CNS will participate in the RUC
process for these codes
…
Read full letter here
