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Comment Letters

Comment Letters
  • 2017 Medicare Physician Fee Schedule (MPFS)
    The Academy submitted comments to CMS on the 2017 Medicare Physician Fee Schedule proposed and final rules. Topics addressed include: practice expense adjustments; revised global surgical data collection requirements; Appropriate Use Criteria for Advanced Diagnostic Imaging requirements; modifications to the QCDR qualification requirements; and updates to the Value Based Modifier and Physician Feedback Programs. 

 

  • 2017 HOPPS and ASC Payment Systems
    The Academy submitted comments on the final rule for 2017 Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment System proposed and final rules. In the comments, the Academy addressed point-of-care imaging access for patients, Appropriate Use Criteria for Advanced Diagnostic Imaging requirements, and changes to Ambulatory Payment Classifications assignments. 

 

  • CMS Listened! AAO-HNS and IAC comment on Medicare Hospital Inpatient Prospective Payment System’s (IPPS) Public Display of Accreditation Status
    • CMS decided not to finalize their proposal to require all Medicare advanced diagnostic imaging final accreditation survey reports as well as acceptable plans of correction (POC) in the FY 2018 IPPS Final Rule.
    • The Academy agreed with comments from the Intersocietal Accreditation Commission (IAC) that any additional transparency that would have been achieved by the proposal would not outweigh the administrative burden on advanced diagnostic imaging accrediting organizations.
    • Further, it could have had adverse effects on the nature of private accreditation processes and resulted in the release of information that is difficult for consumers to access and understand.

 

  • 2016 MPFS
    The Academy submitted comments to CMS on the proposed and final 2016 MPFS rules. The comments addressed 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. 

 

  • 2016 HOPPS and ASC Payment Systems
    The Academy submitted comments on the proposed and final rule for 2016 HOPPS and ASC Payment Systems. The Academy addressed: point-of-care imaging access for patients and changes to Ambulatory Payment Classifications assignments.