ISASS Submits Public Comments on 2024 Medicare Physician Fee Schedule Proposed Rule

On September 11, 2023, ISASS submitted comments to CMS regarding the August 7, 2023, publication of the proposed rule for payment policies for the Medicare Physician Fee Schedule for 2024.

In the comment letter, ISASS also strongly advocated for the maintenance of facility-only reimbursement for Minimally Invasive SI (Sacroiliac) Joint Fusion to ensure payment for the procedure only when performed by surgeons in the OR.  ISASS opposes the interventional pain approach when performed in locations such as offices.

ISASS also commented on proposed relative value units (RVUs) for codes for Lumber Total Disc Replacement, Each Additional Level (CPT code 22860) and Lumbar Total Disc Replacement Primary Level (CPT code 22857). CPT code 22860 was proposed at an RVU of 6.88, which is lower than the RVU of 7.50 that ISASS and other societies recommended through the American Medical Association RVS Update Committee (RUC). ISASS will continue to work with other stakeholders to increase the RVU to 7.50 in alignment with the RUC-recommended RVU. The primary level code for Lumbar Total Disc Replacement (CPT code 22857) was also reviewed by CMS and was maintained at its current work RVU of 27.13, which ISASS agrees with for appropriate payment.

The Medicare Physician Fee Schedule Final Rule is expected to be published in early November and become effective January 1, 2024.

To read the full rule, see here.