Comment Letters

Comment Letters

Academy Submits Comments on CMS Quality Measure Development Plan
The Academy submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the CMS Quality Measure Development Plan: Supporting the Transition to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) (DRAFT). The comments address CMS' strategic vision and approach to the implementation of many critical components of MIPS and APMs. Read the comments.

Academy Submits Comments on Episode Groups to CMS
In preparation for the transition to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMS), the Academy submitted comments to CMS on the development of episode groups. CMS will use care episode groups, patient condition groups and related classification codes to help determine payment rates starting in 2019. Read the letter.

Academy Comments on 2016 Medicare Physician Fee Schedule
The Academy submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the 2016 Medicare Physician Fee Schedule final rule. The comments address several specific payment policy issues affecting otolaryngology including: practice expense changes; Global Surgical Package valuation; Physician Quality Reporting System and Qualified Clinical Data Registry requirements; Physician Compare; and Value Based Payment Modifier program. Read the comments.

Academy Submits Comments on Stage 3 and Modifications to EHR Meaningful Use Final Rule
On December 7, the Academy submitted comments on the CMS final rule regarding Stage 3 and Modifications to the EHR Meaningful Use program. Academy comments focus on the need for increased flexibility, interoperability, continuation of 90-day reporting periods, and measure thresholds and requirements. Read the comments.

Academy Comments on 2016 HOPPS Rule
The Academy submitted comments on the final rule for CY 2016 Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment Rate. The Academy addressed: point-of-care imaging access for patients and changes to Ambulatory Payment Classifications assignments. Read the letter. Read the comments.

Academy Comments on the MACRA RFI
Using feedback solicited from key Academy leaders, the Academy has submitted comments on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Request for Information (RFI). The RFI primarily consists of questions concerning the implementation process for the new Merit-Based Incentive Payment System (MIPS) and eligible Alternative Payment Models (APMs). We anticipate that the newly created MIPS program will significantly impact otolaryngologists and will follow this matter closely. Read the comments

Academy Comments on Proposed 2016 Physician Fee Schedule
On September 8, the Academy submitted comments to CMS regarding the 2016 Proposed Medicare Physician Fee Schedule (MPFS). Topics addressed include: proposed practice expense changes; Global Surgical Package valuation; Physician Quality Reporting System and Qualified Clinical Data Registry (QCDR) requirements; Merit-based Incentive Payment System (MIPPS) establishment; and Alternative Payment Model (APM) regulations. Read the letter.

Academy Comments on Proposed CY 2016 HOPPS 
The Academy submitted comments on the proposed rule for CY 2016 Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment Rate that are specifc to the Otolaryngology community. The Academy commented on: point-of-care imaging access for patients and changes to Ambulatory Payment Classifications assignments. Click here to view the comment letter.  

Academy Comments on CY 2015 MPFS Final Rule
In October CMS released the final rule for the 2015 Medicare Physician Fee Schedule (MPFS). In its 2015 MPFS Final Rule, CMS reiterated its proposal of a  more transparent process for establishing PFS payment rates that will allow for more public input prior to finalizing rates.   CMS finalized that 2016 will be a transition year during which they will propose values for new, revised, and potentially misvalued codes that they receive RUC recommendations in time for inclusion in the 2016 proposed rule. For all others, they will establish interim final values in the 2016 final rule as they have historically done. In addition, CMS finalized changes that increase values for rigid and transnasal esophagoscopy codes,   expand quality reporting options for otolaryngologists, and that continue phasing in the Value Based Payment Modifier.   Notably, CMS is finalizing its proposal to transform all 10- and 90-day global codes to 0-day global codes beginning in CY 2017, revising its proposed list of misvalued codes, and finalizing adjustments to malpractice RVUs among other initiatives.


The Academy has reviewed and summarized the rule as a member benefit and has submitted formal comments on the rule by the December 31st deadline. Click here to view the comment letter.

Academy Submits Comments to CMS on CY 2015 MPFS Proposed Rule
On September 2nd, the Academy submitted comments to the Centers for Medicare & Medicaid Services (CMS) addressing several of their proposals in the CY 2015 Medicare Physician Fee Schedule (MPFS), including transitioning all 10- and 90-day global codes to 0-day global codes over a two year period, identifying approximately 80 codes as “potentially misvalued” and requiring review, and conducting the statutorily mandated update to malpractice RVUs. View the Comment Letter

Academy's Comment Letter on CY 2014 MPFS Final Rule
The Academy submitted comments to CMS by the January 27th deadline on the final rule for the CY 2014 Medicare Physician Fee Schedule. In the letter, the Academy addressed issues that affect Otolaryngology- Head and Neck Surgery. Click below to see the comment letter:

Academy's Comment Letters on CY 2014 MPFS and HOPPS/ASC Proposed  Rules
The Academy submitted comments to CMS by the September 6th deadline on the proposed rules for the CY 2014 Medicare Physician Fee Schedule and the CY 2014 HOPPS/ASC Payments. In the letters, the Academy addressed issues that affect Otolaryngology- Head and Neck Surgery. Click below to see each comment letter:


Academy's CY 2014 Fee Schedule Proposed Rule Comment Letter
Academy's CY 2014 HOPPS/ASC Proposed Rule Comment Letter

Comment Letters on CY 2013 MPFS and HOPPS/ASC Final Rules

The Academy submitted comments to CMS by the December 31st deadline on the final rules for the CY 2013 Medicare Physician Fee Schedule and the CY 2013 HOPPS/ASC Payments. In the letters, the Academy addressed issues that affect Otolaryngology-Head and Neck Surgery. Click below to see each comment letter:

Academy's CY 2013 Fee Schedule Final Rule Comment Letter

Academy's CY 2013 HOPPS/ASC Final Rule Comment Letter

Academy's Comment Letters on CY 2013 MPFS and HOPPS/ ASC Proposed Rule 

On August 28th, 2012, we submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rules for the CY 2013 Medicare Physician Fee Schedule and CY 2013 HOPPS/ ASC Payment. In the letters, the Academy addressed issues that affect otolaryngology- head and neck surgery including quality reporting initiatives, the Sustainable Growth Rate (SGR), and Outpatient and Ambulatory Surgical Center payment. Click below to see each comment letter:

Academy's Comment Letter on the Proposed Rule for CY 2013 Medicare Physician Fee Schedule (MPFS)

Academy's Comment Letter on the Proposed Rule for CY 2013 Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment Rate