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:

1. Mitigate the steep cut to the conversion factor due to multiple changes in evaluation and management (E/M) payment and related policies;
2. Translate the increase E/M values to global surgery codes;
3. Continue coverage and increased payment for telephone only E/M services;
4. Work with Congress to eliminate originating site requirements and geographic restrictions;
5. Withdraw policies that inappropriately expand scope of practice of non-physician practitioners;
6. Work with federal agency partners to remove barriers to electronic prescribing of controlled substances (EPCS);
7. Delay implementation of MIPS Value Pathways (MVPs); and,
8. 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:

1. Delay elimination of the Inpatient Only List (IPO) List, and
2. Eliminate all prior authorizations under the OPPS, but especially for implanted spinal neurostimulators.