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AANS and CNS Comment on Proposed 2022 Medicare Fee Schedule Quality Provisions

On Sept. 13, the AANS and the CNS submitted detailed comments to CMS regarding the 2022 proposed Medicare PFS rule. In the letter, the neurosurgical societies offered the following recommendations related to the rule’s quality provisions:

  • Advised against making the Merit-based Incentive Payment System (MIPS) Value Pathways mandatory;
  • Urged CMS to maintain the current threshold for determining MIPS penalties and bonus payments; and
  • Supported delaying the Appropriate Use Criteria (AUC) Program for advanced diagnostic imaging for another year.

The AANS and the CNS also joined the Alliance in advising against making the MIPS Value Pathways mandatory. Additionally, the neurosurgical societies partnered with the Physician Clinical Registry Coalition (PCRC) in a letter to CMS commenting on issues related to qualified clinical data registries. Finally, the Alliance letter also urged CMS to continue to delay implementation of the AUC Program, as did a Regulatory Relief Coalition (RRC) letter that the AANS and the CNS signed.

Click here to read the AANS/CNS letter, here for the Alliance letter, here for the PCRC letter and here for the RRC letter.