[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-0-en-105":3,"doc-seo-395186-105":59,"doc-detail-395186-en":131},{"code":4,"msg":5,"data":6},0,"success",[7,13,18,23,28,33,38,43,48,51,55],{"id":8,"doc_module":4,"doc_module_name":9,"category_name":10,"show_sort_weight":11,"slug":12},1,"Document","Story & Novel",90,"story-novel",{"id":14,"doc_module":4,"doc_module_name":9,"category_name":15,"show_sort_weight":16,"slug":17},2,"Literature",80,"literature",{"id":19,"doc_module":4,"doc_module_name":9,"category_name":20,"show_sort_weight":21,"slug":22},4,"Exam",70,"exam",{"id":24,"doc_module":4,"doc_module_name":9,"category_name":25,"show_sort_weight":26,"slug":27},5,"Comic",60,"comic",{"id":29,"doc_module":4,"doc_module_name":9,"category_name":30,"show_sort_weight":31,"slug":32},6,"Technology",50,"technology",{"id":34,"doc_module":4,"doc_module_name":9,"category_name":35,"show_sort_weight":36,"slug":37},7,"Healthcare",40,"healthcare",{"id":39,"doc_module":4,"doc_module_name":9,"category_name":40,"show_sort_weight":41,"slug":42},8,"Research & Report",30,"research-report",{"id":44,"doc_module":4,"doc_module_name":9,"category_name":45,"show_sort_weight":46,"slug":47},9,"Religion & Spirituality",20,"religion-spirituality",{"id":46,"doc_module":4,"doc_module_name":9,"category_name":49,"show_sort_weight":46,"slug":50},"World Cup","world-cup",{"id":52,"doc_module":4,"doc_module_name":9,"category_name":53,"show_sort_weight":52,"slug":54},10,"Lifestyle","lifestyle",{"id":56,"doc_module":4,"doc_module_name":9,"category_name":57,"show_sort_weight":24,"slug":58},19,"General","general",{"code":4,"msg":60,"data":61},"ok",{"site_id":62,"language":63,"slug":64,"title":65,"keywords":66,"description":67,"schema_data":68,"social_meta":124,"head_meta":126,"extra_data":128,"updated_unix":130},105,"en","isass-comment-letter-cms-1751-p-cy-2022-revisions-to-payment-policies","ISASS Comment Letter - CMS-1751-P - CY 2022 Revisions to Payment Policies","","September 13, 2021 letter from the International Society for the Advancement of Spine Surgery (ISASS) to CMS requesting reconsideration of the CY 2022 proposed Medicare Physician Payment Schedule changes under file code CMS-1751-P. The letter expresses concern over a proposed 4% decrease in the Medicare conversion factor, warning of reduced reimbursement, access shortages, and risks related to opioid prescribing. ISASS also comments on work and practice expense RVUs, including practice expense labor rate updates, specific CPT code areas, TeleHealth issues, and chronic pain management reimbursement.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":35,"@type":76,"position":81},"https://docshare.wps.com/document/healthcare/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/isass-comment-letter-cms-1751-p-cy-2022-revisions-to-payment-policies/395186/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/isass-comment-letter-cms-1751-p-cy-2022-revisions-to-payment-policies/395186.png","ImageObject",300,407,{"name":92,"@type":93},"AfterMidnight","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-02","2026-09-26",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",11,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What is ISASS’s primary concern about the CY 2022 Medicare conversion factor?","Question",{"text":113,"@type":114},"ISASS strongly objects to the proposed 4% decrease in the Medicare conversion factor, arguing it would drastically reduce Medicare reimbursement and harm access to care.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"What does ISASS recommend CMS do in the final rule regarding the conversion factor?",{"text":118,"@type":114},"ISASS recommends maintaining conversion factors and waiving budget neutrality for physicians and providers under the Medicare Physician Fee Schedule for CY 2022, and taking action to eliminate the reduction.",{"name":120,"@type":111,"acceptedAnswer":121},"Which topics does the letter address beyond the conversion factor?",{"text":122,"@type":114},"The letter covers proposed work and practice expense relative value units, practice expense labor rate and supply/equipment updates, TeleHealth issues, and chronic pain management reimbursement.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},395186,1790624904,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":34,"category_name":35,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":140,"language":141,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":142,"faqs":143,"seo_title":144,"seo_description":67,"update_tm":145,"read_time":146,"preview_page_count":4},962090896061,"https://ap-avatar.wpscdn.com/davatar_9964176cb1d06d4a9deccf72a44ae3dc","September 13, 2021  \nThe Honorable Chiquita Brooks-LaSure Administrator  \nCenters for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS-1751-P  \nMail Stop C4-26-05  \n7500 Security Boulevard Baltimore, MD 21244-1850  \nRe: File Code CMS-1751-P; CY 2022 Revisions to Payment Policies under the Physician Payment Schedule and Other Changes to Part B Payment Policies;  \nDear Administrator Brooks-LaSure:  \nThe International Society for Advancement of Spine Surgery (ISASS) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services (CMS) Notice of Proposed Rule Making (Proposed Rule) on the revisions to Medicare payment policies under the Physician Payment Schedule for calendar year (CY) 2022.  \nISASS is a multi-specialty association dedicated to the development and promotion of the must current surgical standards, as well as the highest quality, most cost-efficient, patient-centric, and proven cutting-edge technology for the diagnosis and treatment of spine and low back pain. The Proposed Rule includes several policy and technical modifications within the Resource-Based Relative Value Scale (RBRVS) .  \nThis letter includes ISASS recommendations and comments regarding the following:  \n• CY 2022 Conversion Factor  \n• Physician Work and Practice Expense Relative Value Unit Recommendations  \no Practice Expense Labor Rate Updates  \no CPT codes 22867  \no 630XX and 630X1  \no 646X0 and 646X1  \n• TeleHealth Issues  \n• Chronic Pain Management Reimbursement  \n2022 Medicare Conversion Factor  \nIn the CY 2022 Proposed Rule, CMS announced an update to the Medicare conversion factor of $33.58 for CY 2022. This represents a 4% decrease from the current (2021) conversion factor of $34.89.  \nISASS is extremely disappointed and concerned with the drastic reduction in the Medicare Conversion Factor and strongly recommends CMS take action in the CY 2022 Final Rule to eliminate this conversation factor reduction.  \nIf the proposed conversion factor changes are implemented, many interventions would see dramatic reductions in total Medicare reimbursement. These procedures are critically important alternatives to past devastating, epidemic opioid-based treatment plans. Several efficacious and cost-effective pain treatments are currently reimbursed at marginal levels, barely covering overhead, and now face drastic reductions if the conversion factor were to be implemented as proposed. These collective reductions would represent a tremendous setback in the efforts by CMS and HHS to effectively address the opioid crisis in the United States and may inadvertently cause a resurgence of opioid prescribing.  \nCMS has done an admirable job in adjusting rules, regulations, and payment rates in response to the current Public Health Emergency due to the Covid-19 crisis. Yet, despite this recognition and all the efforts by CMS to increase access to care for Medicare patients, CMS is proposing the largest single reduction in payment rates to physicians and providers in many years. This is directly contrary to the efforts and the messaging by CMS. If implemented for CY 2022, this unreasonable, proposed reduction would completely undo all the success CMSand physician stakeholders have had in navigating this unprecedented health crisis. If implemented in the final rule, a-4% reduction would cause a massive access shortage as  \npractices reduce staff and hours to absorb the impact. This would result in less access at a time where greater access and greater flexibility is needed in caring for Medicare patients.  \nThe reduced conversion factor constitutes a breaking of trust between physicians, CMS, and patients. Our collaboration and cooperation in overcoming these unprecedented times has been one of the few bright spots in the PHE. Reducing payments to physicians is an unfair and unacceptable response to this collaboration and risks future opportunities for cooperation.  \nCMS should maintain their cooperation and co","cbCaii1KQ93i9iEn","https://ap.wps.com/l/cbCaii1KQ93i9iEn","pdf",314832,22,"English","# CY 2022 Conversion Factor\n## Proposed Work and Practice Expense Relative Value Units\n## Practice Expense Labor, Supply and Equipment Updates\n## TeleHealth Issues\n## Chronic Pain Management Reimbursement","[{\"question\":\"What is ISASS’s primary concern about the CY 2022 Medicare conversion factor?\",\"answer\":\"ISASS strongly objects to the proposed 4% decrease in the Medicare conversion factor, arguing it would drastically reduce Medicare reimbursement and harm access to care.\"},{\"question\":\"What does ISASS recommend CMS do in the final rule regarding the conversion factor?\",\"answer\":\"ISASS recommends maintaining conversion factors and waiving budget neutrality for physicians and providers under the Medicare Physician Fee Schedule for CY 2022, and taking action to eliminate the reduction.\"},{\"question\":\"Which topics does the letter address beyond the conversion factor?\",\"answer\":\"The letter covers proposed work and practice expense relative value units, practice expense labor rate and supply/equipment updates, TeleHealth issues, and chronic pain management reimbursement.\"}]","ISASS Comment Letter - CMS-1751-P - CY 2022 Revisions to Payment Policies | PDF",1790416745,55]