Subject: CMS-1654-P Medicare Program; Revisions to Payment Policies under the
Physician Fee Schedule and Other Revisions to Part B for CY 2017
Dear Mr. Slavitt,
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), representing over 4,000 neurosurgeons in the United States, we appreciate the
opportunity to comment on the above-referenced Notice of Proposed Rulemaking (NPRM). The
following comments focus primarily on the coding, payment and quality provisions included in the rule.
We have submitted comments related to the global surgery proposal in a separate comment letter.
EXECUTIVE SUMMARY
Coding and Reimbursement Issues
Determination of Professional Liability Insurance (PLI) RVUs
- Use of Geographic Practice Costs Indices (GPCI) Updated Data for Specialty-specific Risk Factors for PLI Relative Value Units (RVUs). Neurosurgery has long advocated for the use of the most up-to-date data for PLI RVUs, and we continue to do so. As such, we recommend that CMS use the updated PLI premium data.
- PLI Variation for Low Volume Services. The AANS and CNS urge the agency to accept RUC specialty designation “overrides” for very low volume services to prevent significant variation in year to-year PLI RUVs
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Read full letter here
