Comment Letter

Neurosurgery Comments on Episode-Based Payment Models

  • Quality Improvement and Patient Safety

Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, Maryland 21244

Submitted electronically via

Subject: Request for Information; Episode-Based Payment Model (CMS-5540-NC)

Dear Administrator Brooks-LaSure,

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 the Center for Medicare & Medicaid Innovation’s (Innovation Center) request for input on the design of future episode-based payment models.

The AANS and CNS appreciate the Center for Medicare & Medicaid Services (CMS) effort to build on lessons learned from its experience with the Bundled Payments for Care Improvement (BPCI) initiative and other models to design and implement a new episode-based payment model focused on accountability for quality and cost, health equity and specialty integration, along with the agency’s interest in embedding these types of models within broader population-focused models. However, the request for information (RFI) does not specify any conditions a potential episode-based payment model would target. Thus, given the limited details, the AANS and the CNS request that CMS carefully consider the following broader issues as it contemplates potential future payment models.

Click here to read the full Neurosurgery Comments on Episode-Based Payment Models.