ASRA Pain Medicine Update

Comments on Medicare Proposed Rule Regarding Outpatient and Ambulatory Payments

Oct 18, 2021


n a September 13th letter to the Centers for Medicare and Medicaid Services (CMS), ASRA provided comments regarding the Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center (ASC) Payment Systems and Quality Reporting Programs; Price Transparency of Hospital Standard Charges; Radiation Oncology Model; Request for Information on Rural Emergency Hospitals.

ASRA made the following recommendations:

  • Supported ongoing separate payment for non-opioid pain management drugs and biologicals when they function as surgical supplies in ASCs, as proposed
  • Cautioned against requiring FDA approval with an FDA-approved indication for pain management or analgesia as a criterion for separate payment of non-opioid pain management drugs and biologicals in ASCs. As an alternative, ASRA supports recognition by a medical compendium or recommendations of specialty societies or national organizations in lieu of an FDA-approved indication for pain management or analgesia.
  • Suggested that CMS provide separate payment for non-opioid pain management treatments including nerve blocks, surgical injections, and neuromodulation when used in surgical procedures performed in the ASC setting.
  • Supported CMS’s proposal to halt the elimination of the Inpatient Only (IPO) list and to add the services removed from the IPO list for CY 2021 back to the IPO list in CY 2022.
  • Invited CMS to work with ASRA to develop meaningful, low-burden measures focused on pain management surgical procedures that should be used across health care settings.

Read the full letter.

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