The NANS Advocacy and Policy Committee recently provided a joint letter to comment on the Centers for Medicare & Medicaid Services (CMS) Notice of Proposed Rule Making (Proposed Rule) on the revisions to Medicare policies under the Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Payment Systems for calendar year (CY) 2023.

Read more about the comments.

May 3, 2021

The Advocacy and Policy Committee would like to bring to your attention some very recent updates put forth by Medicare (CMS) concerning prior authorization. This past March, CMS adopted a new rule requiring prior authorization (PA) for selected Implanted Spinal Neurostimulator (SCS) procedures performed in an Outpatient Hospital Department (OPD) for dates of services on or after July 1, 2021.

Click here to learn more about the potential impact to SCS patients and providers due to these new requirements.

March 29, 2021

The NANS Advocacy and Policy Committee would like to inform all NANS members that the final policy concerning Facet Joint Interventions for Pain Management has now been shared by all current Medicare Administrative Contractors (MACs). The final policy is effective April 25, 2021. This new policy was developed and adopted by all the MACs and therefore represents equivalent coverage across the states.

View the Response to Comments article.
Learn more about the new policy and the associated billing and coding processes.

February 5, 2021

The NANS Advocacy and Policy Committee recently participated, with partners in the Multi-Society Pain Working Group, on a letter submitted to the Medicare Administrative Contractor Medical Directors. The letter supports coverage of epidural injections for chronic pain management, and provides a detailed explanation of their importance to Medicare patients’ quality of life.

We wanted to share this letter with our members as well, so that you would be aware of the efforts being made on behalf of our members, patients and specialty.

View the letter here.

January 22, 2021

The Advocacy and Policy Committee was recently made aware of several Medicare fee schedule changes that impact a series of Neuromodulation codes.

Changes were enacted from 2020 to the 1st Quarter of 2021 for a series of commonly used neuromodulation and interventional pain management procedure CPT codes. These are for the Medicare rates for physician work and not the facility fee assigned by Medicare and paid to the ASC or Outpatient facility. Those rates are set in a different fee schedule and had an overall increase in payments for 2021, along with other changes.

Access a complete review of the codes that are impacted here.

December 14, 2021

The Advocacy and Policy Committee would like to inform NANS members of recent CPT changes to office and other outpatient codes that may affect your practice(s).

The CPT Editorial Panel has recently approved revisions to the Current Procedural Terminology (CPT) Evaluation and Management (E/M) office or other outpatient services codes, which will have significant implications on coding and documentation for these vital services. We encourage you to learn more about these changes and how they will impact your work. The changes are scheduled to go into effect January 1, 2021. In addition, CMS has approved updated Relative Value Unit settings for the E/M code set.

As a resource, the Advocacy and Policy Committee has crafted a reference document that you can reference here.

September 28, 2020

The NANS Advocacy and Policy Committee recently commented on the Centers for Medicare & Medicaid Services (CMS) Notice of Proposed Rule Making (Proposed Rule) on the revisions to Medicare policies under the Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Payment Systems for the calendar year (CY) 2021 as well as the CMS Notice of Proposed Rule on the revisions to Medicare payment policies under the Physician Payment Schedule for the calendar year (CY) 2021.

The APC has provided copies of the letters below.

NANS Comments on Outpatient Prospective Payment

NANS Comments on Physician Payment Schedule

The APC organized a response to the Medicare Administrative Contractor (MAC) Medial Directors for providing information and transparency to the Committee (CAC) Meeting Regarding Facet Joint and Medial Nerve Branch Procedures.

NANS offered input to help provide greater background and understanding of facet procedures and its literature to help the workgroup in their assessment. NANS believes facet procedures are of the most important tools pain physicians use to control chronic neck and back pain, and it's critical that the MACs ensure proper coverage guidelines.

Please read the Advocacy and Policy's response here.

Recently, NANS partnered with 11 other medical specialty societies to send letters to both Novitas and First Coast containing comments on their proposed Local Coverage Determinations for Percutaneous Vertebral Augmentation for Vertebral Compression Fractures, DL35130 and DL34976, respectively.

Click here to view a copy of the Multisociety Comment Letter on Proposed LCD DL35130 to Novitas.

Click here to view the Multisociety Comment Letter on Proposed LCD DL34976 to First Coast.

NANS, along with nine other medical specialty societies, convened to review and comment on the Oregon Health Authority's Public Health Division's proposed regulations that would expand opportunities for advanced practice providers to supervise procedures performed under fluoroscopic guidance.

To see a copy of the submitted Position Statement on Prerequisite Training for the Performance of Spine Interventions as well as the AMA's Pain Management Practice Parameter (H-410.950), click HERE.

The NANS Advocacy and Policy Committee, on behalf of the membership, recently submitted comments to the CMS focusing on the CMS Physician Fee Schedule and ASC/HOPD Fee Schedule Proposals for 2020. NANS applauds the efforts of CMS to incentivize non-opioid treatment options in order to reduce the scale of the opioid crisis facing this company. For this reason, NANS strongly encouraged CMS to facilitate chronic pain patient access to opioid alternative treatments. NANS’ comments also emphasized that assigning inappropriately low work and practice expense relative value units (RVUs) to non-opioid options, such as injections, ablations, pain reservoir analysis and refills would contradict this effort. All these pain services are clinically efficacious alternative to opioids for pain management.

NANS believes it is critical that CMS adopt revised global period RVUs if they move forward with implementing increases to office visit Evaluation and Management codes in CY 2021. NANS’ comments also include a request for CMS to revoke the proposal to remove Medicare billing privileges without adding greater transparency and appeal processes for physicians having their privileges reviewed. Lastly, NANS requests that CMS maintain the current assignment of interspinous spacer devices to its current, CY 2019, APC assignment of 5116 rather than reassigning to APC 5115 as proposed for CY 2020.

To see a copy of "Comments to CMS on Proposed Physician Fee Schedule for 2020," click HERE.

To see a copy of "Comments to CMS on Proposed ASC/HOPD Fee Schedule for 2020," click HERE.

The RUC Survey Process

The NANS Advocacy and Policy Committee has prepared a memo to all members with an overview and understanding of how the RUC survey process works and why it is important for NANS members to participate. NANS has formal seats on the RUC and CPT boards, and this is one of the activities we are able to participate in.