RE: CMS-1590-P Medicare Program; Payment Policies Under the Physician Fee
Schedule (PFS) and Other Revisions to Part B for CY 2013
Dear Administrator Tavenner:
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), we appreciate the opportunity to comment on the above referenced Notice of Proposed
Rulemaking (NPRM) published in the Federal Register on July 30, 2012. Below are our views on a
number of payment and quality issues.
SUMMARY OF COMMENTS
Valuation Issues
- Practice Expense (PE) for Low Volume Services. The AANS and CNS concur with the RUC
concerns about the difficulty of establishing PE values for CPT codes reported for Medicare fewer
than 100 times in a year. We urge CMS to seek input from the appropriate dominant specialties
for these codes, similar to the policy established by CMS in 2011 for Professional Liability
Insurance for low volume services.
…
Read full letter here
