Response to CMS on Proposed Physician Fee Schedule for 2020

The NANS Advocacy and Policy Committee, on behalf of the membership, recently submitted comments to the CMS focusing on the CMS Physician Fee Schedule and ASC/HOPD Fee Schedule Proposals for 2020. NANS applauds the efforts of CMS to incentivize non-opioid treatment options in order to reduce the scale of the opioid crisis facing this company. For this reason, NANS strongly encouraged CMS to facilitate chronic pain patient access to opioid alternative treatments. NANS’ comments also emphasized that assigning inappropriately low work and practice expense relative value units (RVUs) to non-opioid options, such as injections, ablations, pain reservoir analysis and refills would contradict this effort. All these pain services are clinically efficacious alternative to opioids for pain management.

NANS believes it is critical that CMS adopt revised global period RVUs if they move forward with implementing increases to office visit Evaluation and Management codes in CY 2021. NANS’ comments also include a request for CMS to revoke the proposal to remove Medicare billing privileges without adding greater transparency and appeal processes for physicians having their privileges reviewed. Lastly, NANS requests that CMS maintain the current assignment of interspinous spacer devices to its current, CY 2019, APC assignment of 5116 rather than reassigning to APC 5115 as proposed for CY 2020.

To see a copy of "Comments to CMS on Proposed Physician Fee Schedule for 2020," click here. 

To see a copy of "Comments to CMS on Proposed ASC/HOPD Fee Schedule for 2020," click here.