NANS Comments on CMS CY 2025 Proposed Rule Making

The North American Neuromodulation Society (NANS) crafted a letter in response to the CMS Proposed Rule Making (Proposed Rule) on the revisions to Medicare payment policies under the Physician Payment Schedule (PFS) for calendar year (CY) 2025. The letter includes NANS' recommendations and comments regarding the CY 2025 Proposed Conversion Factor, Prior Authorization for Spinal Cord Stimulation (SCS), Telehealth Services under PFS.

The CY 2025 Proposed Conversion Factor is a 2.8% decrease from the current CY 2024 conversion factor. If the proposed conversion factor changes are implemented, most neuromodulation interventions would see another year of dramatic reductions in total Medicare reimbursement. These procedures are critically important to preserving the quality of life for millions of Medicare patients with a plethora of diagnoses. NANS respectfully requests that CMS eliminates this proposed reduction in physician payment to ensure access for Medicare patients.

Epidural SCS has been shown time and time again to improve patient’s quality of life, reduce their use of dangerous and addicting opioid medications, and reduce health system utilization. CPT code 63650 (percutaneous implantation of SCS electrode) was added to the CMS prior authorization list in CY 2021 for procedures performed in the hospital outpatient department (HOPD), leading to great additional costs to physician practices. It should be noted that SCS trials and implants performed in an ASC setting do not require prior authorization. NANS requests that CMS removes the requirement for prior authorization for SCS trials and implants performed in the HOPD.

For CY 2025, CMS has multiple proposals for Telehealth services under the PFS. NANS supports the Telehealth proposals outlined in the proposed rule. NANS members and patients have experienced the benefits of utilizing telehealth for the programming of SCS and deep brain stimulation (DBS). CMS continues to maintain the codes for these services on the provisional telehealth services list, rather than move them to the list of services for permanent provision via telehealth. As of December 31, 2024, temporary flexibilities enacted due to the COVID-19 public health emergency will expire. We hope that Congress will extend these temporary changes through 2025. We also request that CMS place DBS and SCS programming services on the list of services permanently approved for provision via Telehealth.

The CMS Final Rule will be released on or around November 1, 2024, with the Medicare fee-schedule changes effective January 1, 2025. 

Click here to read the letter PDF.


Get Involved

A Dear Colleague letter by Reps. Mariannette Miller-Meeks (R-IA) and Jimmy Panetta (D-CA) urges Congress to expeditiously pass legislation replacing the impending 2.8% cut with a payment update reflective of inflationary pressures on medical practices. As of September 30, more than 190 bipartisan members of Congress have agreed to cosign the letter.
 
The letter will remain open for additional House members to cosign through close of business on Friday, October 11, which needs 218 cosigners to represent majority of Congress. 

See if your member of Congress is on the current tally of cosigners here. If they are not, please use the American Medical Association's Physicians Grassroots Network email tool to urge them to support the letter by October 11.

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