Comments on Medicare Program, CY 2021 Address Multiple ConcernsOct 5, 2020
Friday, ASRA submitted comments to the Centers for Medicare and Medicaid Services regarding a number of aspects of two proposed rules.
In a letter to Administrator Seema Verma, MPH, ASRA presented feedback on several issues regarding CMS-1723-P:
- Mitigate the steep cut to the conversion factor due to multiple changes in evaluation and management (E/M) payment and related policies;
- Translate the increase E/M values to global surgery codes;
- Continue coverage and increased payment for telephone only E/M services;
- Work with Congress to eliminate originating site requirements and geographic restrictions;
- Withdraw policies that inappropriately expand scope of practice of non-physician practitioners;
- Work with federal agency partners to remove barriers to electronic prescribing of controlled substances (EPCS);
- Delay implementation of MIPS Value Pathways (MVPs); and,
- Retain the current (Year 4) MIPS Quality and Cost performance category weights and performance thresholds, in light of COVID-19 pandemic efforts.
In a letter to Administrator Verma regarding CMS-1736-P, ASRA addressed issues regarding:
- Delay elimination of the Inpatient Only List (IPO) List, and
- Eliminate all prior authorizations under the OPPS, but especially for implanted spinal neurostimulators.