ISASS Comments on 2021 Medicare Outpatient Prospective Payment System/Ambulatory Surgical Center (OPPS/ASC) Proposed Rule

ISASS submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) on the 2021 OPPS/ASC Proposed Rule on October 2, 2021.

The ISASS letter addressed several areas of interest and relevance to ISASS members, including the proposed reduction in Medicare physician payments for 2021.

In the letter, ISASS objected to the CMS proposal to require prior authorization for cervical fusion and spinal neurostimulator simulation procedures performed in the OPPS or ASC settings. ISASS cited several published studies on the costs to patients and providers with prior authorization requirements and urged CMS to revise their proposal and not require prior authorization for these procedures.

ISASS also commented on the proposed elimination of the Inpatient Only list that limits certain surgical procedures to the inpatient setting. CMS proposed to eliminate the list, thus allowing all surgeries to be performed in outpatient settings. ISASS advised the agency to proceed cautiously, as the proposal could lead to patient safety issues for high-risk procedures, including several spine surgical procedures.

CMS will publish the OPPS/ASC Final Rule in December 2020, to go into effect on January 1, 2021.

A copy of the ISASS letter can be found here: ISASS OPPS-ASC Proposed Rule Comment Letter