Comment Letter

Neurosurgery Leads Effort to Improve Spine Care Reimbursement

  • Reimbursement and Practice Management

Meena Seshamani, MD, PhD
Deputy Administrator and Director, Center for Medicare
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Subject: Medicare Device Payment Policy for Add-on Codes

Dear Dr. Seshamani,

On behalf of the American Association of Neurological Surgeons (AANS), American Association of Orthopaedic Surgeons, Congress of Neurological Surgeons (CNS), AANS/CNS Joint Section on Disorders of the Spine and Peripheral Nerves, International Society for the Advancement of Spine Surgery, Lumbar Spine Research Society, North American Spine Society, Scoliosis Research Society and Society for Minimally Invasive Spine Surgery, representing practicing neurosurgeons and orthopaedic spine surgeons in the United States and the patients they serve, we are writing to urge the Centers for Medicare & Medicaid Services (CMS) to take action to ensure access to care for certain spine procedures performed in hospital outpatient departments (HOPDs) and ambulatory surgery centers (ASCs). Specifically, we recommend that CMS modify its current HOPD and ASC payment policy to better account for procedure combinations involving add-on codes using implanted devices.

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