AAO-HNS Comments on Medicare Physician Fee Schedule Final Rule

On December 30, the AAO-HNS submitted comments to CMS regarding the CY 2020 Medicare Physician Fee Schedule final rule. In the November 15 federal register notice rule publication, the agency indicated its willingness to solely consider comments on the sections of the rule describing changes to coding and payment for E/M services. Therefore, the Academy’s comment letter reiterated our concerns with the overall E/M coding restructure scheduled to take effect in 2021. Our comments also strongly encourage CMS to reconsider the decision not to apply the increased E/M payments to the corresponding E/M values in the global surgery package.