Subject: CMS-1676-P Medicare Program; Revisions to Payment Policies Under the
Physician Fee Schedule (PFS) and Other Revisions to Part B for CY 2018
Dear Administrator Verma:
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate the
opportunity to comment on the above-referenced notice of proposed rulemaking.
EXECUTIVE SUMMARY
Regulatory Reform
Global Surgery Data Collection Project
- The AANS and CNS urge CMS to delay the global surgery data collection project – both claims data and the provider survey – until CMS has addressed outstanding project issues and conducted adequate provider education.
- We recommend that the agency avoid using any data collected in 2017 to revalue global services in 2019, particularly until the validity of such data can be ascertained.
- The AANS and CNS urge CMS to suspend the practitioner survey until it has been thoroughly vetted and the specialties to be surveyed have had an opportunity to review it and provide feedback.
- If CMS can collect useful data, we request that the agency refrains from modifying values for those CPT codes subject to data collection outside of the well-established American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC) process.
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