RE: CMS-1612-P Medicare Program; Payment Policies Under the Physician Fee Schedule
(PFS) and Other Revisions to Part B for CY 2015
Dear Administrator Tavenner,
On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological
Surgeons (CNS), representing over 4,000 neurosurgeons in the United States, we appreciate the
opportunity to comment on the above referenced Notice of Proposed Rulemaking (NPRM) published in
the Federal Register on July 11, 2014. The following comments will focus on the Physician Compare
website, Physician Quality Reporting System (PQRS), and Value-Based Payment Modifier (VM)
Programs. We have submitted comments related to the non-quality proposals in separate comment
letters.
Summary of Comments
- Physician Compare
- The AANS and CNS are extremely concerned about the aggressive timeline over which CMS
plans to publicly report physician performance data. Two years is an insufficient amount of time
to evaluate the accuracy, relevancy, and meaningfulness of publicly reported group practice data
and to apply lessons learned to individual level data. - We support giving specialty societies the option to publicly report their measures via their own
websites linked to Physician Compare so long as the measures are grounded in evidence,
developed by relevant clinical experts, and have been adequately vetted. - CMS should not publicly report composite scores until it has further studied the accuracy and
relevance of calculating composite scores. - While we value patient experience data for internal quality improvement purposes, we oppose the
public reporting of CAHPS or other patient experience survey data due to the subjectivity of these
surveys, potential perverse incentives to keep the patient satisfied, and the cost of administering
the surveys.
- The AANS and CNS are extremely concerned about the aggressive timeline over which CMS
…
Read full letter here
