Subject: CMS-1695-P Medicare Program: Calendar Year 2019 Hospital Outpatient
Prospective Payment and Ambulatory Surgical Center Payment Systems and
Quality Reporting Programs
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
REIMBURSEMENT ISSUES
Outpatient Prospective Payment System Issues
- . Magnetic Resonance-guided Focused Ultrasound for Essential Tremor (MRgFUS). The AANS and CNS urge CMS not to implement payment policy that would lower the reimbursement for this promising new technology.
Ambulatory Surgery Center Issues
- . Device Intensive Procedures. The AANS and CNS support the CMS proposal to lower the device-intensive threshold to 30 percent.
- . Policy Proposals Regarding the ASC-Payable List. The AANS and CNS note that CMS will be reviewing procedures added to the ASC list over the last three years. We urge CMS to study available data and consult appropriate stakeholders regarding the safety of performing surgery in the ASC setting. Ultimately, we believe the site of service should be determined by the operating surgeon in consultation with the patient.
- . Non-Opioid Alternatives for Pain Treatment. The AANS and CNS commend CMS for efforts to promote the use of effective alternatives to opioid treatment for pain.
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