AANS/CNS Comment on Proposed 2023 Medicare Hospital Outpatient Rule
On Sept. 12, the AANS and the CNS submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the 2023 Medicare Hospital Outpatient Prospective Payment (OPPS)/Ambulatory Surgery Center Payment System proposed rule. In the letter, the neurosurgical groups agreed with the agency’s plan to remove the arthrodesis CPT code 22632 from the inpatient-only (IPO) list and to add the new CPT code 228XX (additional level total disc arthroplasty procedures) to the IPO list. The comments stressed that the site of service should be determined by the surgeon in consultation with the patient.
The AANS and the CNS also reemphasized that CMS should rescind the prior authorization requirements for spinal cord stimulator and cervical spine procedures when performed in the hospital outpatient department. Neurosurgery also joined the Regulatory Relief Coalition (RRC) in urging CMS to drop the spine-related procedures from the list of hospital outpatient services subject to prior authorization.