Neurosurgery Opposes Expanding Prior Auth to ASCs

William N. Parham, III
Director, Division of Information Collections and Regulatory Impacts
Office of Strategic Operations and Regulatory Affairs Division of Regulations Development
Centers for Medicare & Medicaid Services
Room C4-26-05
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Submitted electronically to

Re: Prior Authorization Demonstration for Certain Ambulatory Surgical Center (ASC) Services (CMS-10884)

Dear Mr. Parham,

The Regulatory Relief Coalition (RRC) is pleased to have the opportunity to comment on CMS’ notice (the PA ASC Notice) announcing its intention to collect information from the public in conjunction with a potential demonstration project that would require Ambulatory Surgical Centers (ASCs) to obtain prior authorization (PA) before providing certain surgical procedures (Selected Procedures) to Medicare beneficiaries. The RRC is a coalition of national physician specialty organizations seeking to reduce regulatory burdens that interfere with patient care. Our recent activities focus on ensuring that utilization review policies are not a barrier to timely and equitable access to care for the patients we serve. The RRC has several questions and concerns regarding the proposed information collection activity.

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