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Seema Verma, MPH, Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G
200 Independence Avenue, SW
Washington, DC 20201

Submitted electronically via www.regulations.gov

Subject: CMS-1693-P Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule (PFS) and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program

Dear Administrator Verma:

On behalf of the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate the opportunity to comment on the above-referenced notice of proposed rulemaking.

EXECUTIVE SUMMARY

CODING AND REIMBURSEMENT ISSUES

Practice Expense (PE) Issues

• The AANS and CNS support the practice of using input from the American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC) and expert stakeholders for the assignment of dominant specialty for PE service with a low volume in the Medicare population, as long as all relevant specialties have been consulted and agree.
• Regarding the CMS review of PE for clinical labor tasks, we agree with the RUC, the American College of Surgeons (ACS) and other stakeholders that CMS seems to fundamentally misunderstand the issue of standards for clinical labor activities. We urge the agency to review the RUC and ACS comments on this issue thoroughly.
• Neurosurgery agrees with concerns expressed by the ACS, RUC and others regarding the contract with StrategyGen to update supply and equipment pricing. We urge the agency to work with the RUC to allow more transparency of the updates proposed by StrategyGen. We support the ACS request for a delay in implementation, and at a minimum, to accept the RUC request to…

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