Re: CMS-1613-P Medicare and Medicaid Programs: Hospital Outpatient Prospective
Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting
Programs Proposed Rule
Dear Ms. Tavenner:
On behalf of 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 refereneced Centers for Medicare and Medicaid Services’ (CMS) 2015 Hospital
Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems and
Quality Reporting Programs Proposed Rule. In particular, we would like to highlight policies affecting two
important areas of neurosurgery — Stereotactic Radiosurgery (SRS) and Deep Brain Stimulator (DBS)
treatment. The policies included in the proposed rule will have a significant impact on patient access to
these important life-saving treatments; thus as the agency moves to establish comprehensive Ambulatory
Payment Classifications (APCs), the details are crucial to ensure that all of the costs are accounted for and
adequately reimbursed. We are encouraged in the case of SRS that the agency has improved the data it is
using to establish comprehensive APCs, but do not believe the same can be said for DBS. We appreciate
your consideration of the following comments.
Stereotactic Radiosurgery
Last year we had grave concerns regarding the 2014 Medicare Hospital OPPS proposed rule’s impact on
reimbursement for SRS and provided extensive comments. We are cautiously optimistic that CMS has
listened and its plan to establish a comprehensive APC for single session cranial stereotactic radiosurgery
as proposed, in combination with the reimbursement level for C-APC 0067 posted in Addendum B, seems
reasonable. We thank the agency for its continued review and we do not object to comprehensive APCs if
they are based on accurate and robust data sets. We urge CMS to monitor the new comprehensive C-APC
0067 to be sure it establishes fair, adequate and stable reimbursement in the future. Further, for CY 2015,
we urge CMS to refrain from making any technical or policy changes that could result in a decrease to the
proposed payment level for C-APC 0067 to ensure that patients continue to have access to these important
procedures. We also support CMS’ proposal to revise the descriptor for APC 0067 to “Single Session
Cranial Stereotactic Radiosurgery.” This adjustment accurately reflects the full scope of services and
technologies that should fall within this C-APC, an essential issue in any bundling plan.
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Read full letter here
