Subject: CMS-1693-P Medicare Program; Revisions to Payment Policies Under the
Physician Fee Schedule (PFS) and Other Revisions to Part B for CY 2019;
Medicare Shared Savings Program Requirements; Quality Payment Program; and
Medicaid Promoting Interoperability Program
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
CODING AND REIMBURSEMENT ISSUES
Practice Expense (PE) Issues
- The AANS and CNS support the practice of using input from the American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC) and expert stakeholders for the assignment of dominant specialty for PE service with a low volume in the Medicare population, as long as all relevant specialties have been consulted and agree.
- Regarding the CMS review of PE for clinical labor tasks, we agree with the RUC, the American College of Surgeons (ACS) and other stakeholders that CMS seems to fundamentally misunderstand the issue of standards for clinical labor activities. We urge the agency to review the RUC and ACS comments on this issue thoroughly.
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