Subject: Fiscal Year (FY) 2020 Medicare Hospital Inpatient Prospective Payment System
(IPPS) and Long Term Acute Care Hospital (LTCH) Prospective Payment System
Proposed Rule, CMS-1716-P
Dear Administrator Verma,
On behalf of more than 4,000 practicing neurosurgeons in the United States, the American Association of
Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS) appreciate the
opportunity to comment on the above-referenced CMS hospital inpatient prospective payment system
proposed rule.
SUMMARY OF COMMENTS
PAYMENT PROVISIONS
New Technology Add-On Payment General Issues
- Proposed New Technology Add-on Payment Alternative Pathway for Devices
- The AANS and the CNS support the agency’s proposal to streamline the process for new technology add-on payment status for medical devices that receive clearance through the Food and Drug Administration (FDA) Breakthrough Devices Program.
- Proposed Increase for New Technology Add-on Payment
- The AANS and the CNS support the CMS proposal to increase new technology add-on payment from 50% to 65% of the lesser of the costs of the new medical technology or the amount by which the costs of the case exceeds the standard DRG payment.
- Request for Information (RFI) on New Technology Substantial Clinical Improvement Criterion
- The AANS and the CNS appreciate the agency’s interest in increasing transparency and providing greater predictability for new technology add-on payment applicants.
Read full letter here
