Earlier this month, the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS) submitted comments concerning several aspects of the 2015 Medicare Physician Fee Schedule Proposed Rule released by the Centers for Medicare and Medicaid Services (CMS). Our comment letters addressed the following topics:
- The AANS and CNS strongly oppose eliminating the 10- and 90-day surgical global periods.
- The AANS and CNS support implementing an improved schedule for adopting new values and urge CMS to institute a meaningful appeal and review process.
- The AANS and CNS are long-time proponents of private contracting for Medicare patients and support the ability of physicians to opt-out of the program without filing an affidavit every two years to remain in an opt-out status.
- The AANS and CNS oppose the proposal to increase PQRS reporting requirements and eliminate several surgery quality measures, as this will leave neurosurgeons with few, if any, relevant and meaningful mechanisms by which to participate. This is especially concerning as the PQRS transitions to an all-penalty program, under which physicians face annual quality reporting penalties of over ten percent in the coming years.
- The AANS and CNS oppose the proposed timeline for tying Medicare payments to physician performance via the Value-Based Payment Modifier (VBM) and for public reporting physician performance data because it is much too aggressive and leaves little opportunity to evaluate the data’s accuracy, its relevance to patients and physicians, and the impact on smaller practices and individual physicians.
- The AANS and CNS support the PQRS Qualified Clinical Data Registry (QCDR) reporting option; however, many existing and proposed requirements will make it challenging, if not impossible, for specialties to take advantage of this option and contradict the flexibility it was intended to afford.
- The AANS and CNS strongly oppose the proposal to eliminate the CME exemption from the Physician Sunshine Open Payment system. The current exemption, which requires compliance with the rigorous Accreditation Council for Continuing Medical Education’s (ACCME) Standards for Commercial Support: Standards to Ensure Independence in CME Activities, meets the goals of the Sunshine Act. At a minimum, a change in the CME policy should be delayed until organizations and CMS can fully analyze the impact of the proposal to eliminate the current exemption.
Working with our colleagues in the Surgical Coalition, the AANS and CNS succeeded in getting over 20 members of Congress to write a letter to CMS urging the agency to scrap the proposal to eliminate the global surgery package. Furthermore, organized neurosurgery will continue to press CMS to address our other concerns with the proposed rule.