Regulatory Advocacy

The AAO-HNS has a long history of working closely with regulatory agencies (e.g., Centers for Medicare & Medicaid Services, U.S. Food and Drug Administration) to maintain our visibility and credibility with national representatives regarding federal regulatory issues.

We believe that advocacy is the key to defining the future of otolaryngology. Federal regulatory advocacy is a top priority of the AAO-HNS.

*NEW* Advocacy Update on CMS' Proposed Exclusion of Coverage of Osseointegrated Implants (9/2/2014) 

Background
The Centers for Medicare & Medicaid Services (CMS) published a proposed rule focusing on the 2015 Durable Medical Equipment Prosthetics Orthotics and Supplies (DMEPOS) fee schedule. Notably, part of the proposed rule specifies that the Medicare reimbursement exclusion for hearing aids will now encompass all types of air conduction and bone conduction auditory prosthetics (external, internal, or implanted). If finalized, the proposed rule would negate CMS' current coverage of osseointegrated implants. To view the rule, click here.

Advocacy Efforts
In response to the proposed rule, Academy leadership and health policy staff have advocated on multiple levels and engaged Academy committees, and sister specialty societies and other leaders among our membership (within Otology/Neurotology as well as health policy and government affairs staff) to craft comments that best represent our members and our patients. More specifically, Academy leadership and staff conferenced individually and collectively with members and chairs of the Hearing and Implantable Hearing Devices Committees to gather specific examples and feedback on how the proposed rule, if enacted, would negatively impact thousands of patients who have no other recourse to better hearing. Further, the Academy participated in three direct meetings with CMS, various audiology and public interest group conferences, and meetings with presidents of ANS and AOS. All of these efforts were directed at raising awareness of the significant potential impact of this proposed rule and garnering support in defense of our position.

On September 2, 2014, the Academy, AOS, and ANS submitted a formal joint comment letter to CMS noting concerns about the proposal and providing a suggested alternative to the proposed rule that would allow for continued coverage of osseointegrated implants for Medicare patients.

We will continue to closely monitor the matter and will be sure to keep members apprised of pertinent information via the eNews, HP Update, website, and other outreach tools. Members are encouraged to regularly check the Regulatory Advocacy page for important announcements and opportunities to positively affect change with government agencies.

NEW*  CMS Issues  2015 Proposed Rule for the Medicare Physician Fee Schedule  (7/10/2014)

Last week, CMS released the proposed 2015 Medicare Physician Fee Schedule (MPFS) proposed rule. In its 2015 MPFS Proposed Rule, CMS is proposing a new  more transparent process for establishing PFS payment rates that will allow for more public input prior to finalizing rates.  Under the new process, payment changes will go through notice and comment rulemaking before being adopted beginning for 2016.  In addition, CMS is proposing changes to several quality reporting initiatives, changes to the Physician Compare Website and to continue phasing in of the Value Based Payment Modifier.   Notably, CMS are also proposing to transform all 10- and 90-day global codes to 0-day global codes beginning in CY 2017, proposing to add roughly 80 codes to its list of potentially misvalued codes, and proposing adjustments to malpractice RVUs among other initiatives. For more on the proposed rule, see the CMS Fact Sheet on the Rule

The Academy has reviewed and summarized the rule as a member benefit. Individual members are encouraged to submit individual comments at the Federal Register website.