Re: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care
Hospitals and Long-Term Care Hospital Prospective Payment System and
Proposed Fiscal Year (FY) 2015 Rates; Quality Reporting Requirements for Specific
Providers
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 above referenced Centers for Medicare and Medicaid Services’ (CMS)
hospital inpatient prospective payment system proposed rule.
SUMMARY OF COMMENTS
Proposed Changes to MS-DRG Classifications and Relative Weights
- Back and Neck Procedures. The AANS and CNS support the proposal to delete MS-DRGs 490
and 491 and create three new back and neck MS-DRGs to better describe these procedures - Add-On Payments for New Services and Technologies. The Responsive Neurostimulator (RNS)
System represents a significant clinical improvement for epilepsy patients who are refractory to
medical or surgical treatment, and therefore, the AANS and CNS agree that this new technology
meets the “substantial clinical improvement criterion” set forth by CMS. - Proposed Medicare Code Editor (MCE) Changes. The AANS and CNS support the proposal to
removed intracranial-extracranial bypass procedures from the non-covered procedure list.
Other Proposed Decisions and Changes to the IPPS for Operating Costs
- Hospital Readmission Reduction Program.
− The AANS and CNS are pleased that CMS has not proposed to add any new measures to the
HAC Reduction Program or the HAC/Present on Admission Program.
− Neurosurgery believes that CMS must exclude readmission for conditions that are related to the
original admission.
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Read full letter here
