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Neurosurgery Comments on Proposed 2024 Medicare Physician Fee Schedule

On Sept. 6, the AANS and the CNS submitted comments on the Calendar Year (CY) 2024 Medicare Physician Fee Schedule Proposed Rule. The neurosurgical groups expressed concerns about the 3.5% decrease in the CY 2024 conversion factor, primarily stemming from a new office visit add-on code (G2211) for complex services. In their letter, the AANS and the CNS urged the Centers for Medicare & Medicaid Services (CMS) to:

  • Halt implementation of the G2211 add-on code;
  • Adjust the 10- and 90-day global codes to reflect increases in the value of post-operative evaluation and management services; and
  • Accept the American Medical Association/Specialty Society Relative Value Scale Update Committee-recommended values for the total disc arthroplasty code (CPT code 22860).

The AANS and the CNS also commented on Medicare’s Quality Payment Program issues. Among other things, the letter:

  • Objected to the new Merit-Based Incentive Payment System Value Pathways framework;
  • Requested that CMS maintain measure #128: Body Mass Index Screening so that it is available to specialists who otherwise have access to very few relevant measures; and
  • Registered concerns about the flawed approach to cost measurement and the inclusion of surgeons in the newly developed Low Back Pain episode-based cost measure, which is aimed at evaluating non-operative, chronic care.

Responding to neurosurgery’s ongoing advocacy, CMS proposed suspending the implementation of the Appropriate Use Criteria for Advanced Diagnostic Imaging Program due to unsurmountable operational challenges and a reassessment of the program’s utility.

Besides their letter, the AANS and the CNS joined several coalition letters. Click here for a surgical coalition letter opposing the G2211 add-on code, here for the Alliance of Specialty Medicine letter and here for the Physician Clinical Registry Coalition letter.

For additional details about the proposed rule, click here for a summary of provisions of interest to neurosurgery and here for a CMS fact sheet.

September E-News