The AAN Comments on the CY 2012 Physician Fee Schedule

September 9, 2011

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On August 30, the Academy sent comments to the Centers for Medicare and Medicaid Services (CMS) on the agency's proposed changes to the Physician Fee Schedule for 2012. The AAN's comments focused on the proposed addition of several neurologic measures to the Physician Quality Reporting System (PQRS) and a potential revaluation of evaluation and management (E/M) codes.

The AAN fully supports CMS's proposal to add quality measures developed by the Academy to PQRS in Parkinson's disease, epilepsy, dementia, and sleep apnea.

Additionally, the AAN supports CMS's proposal to revaluate all E/M codes noting that the US health care system has changed from an episodic-based system to one focusing on caring for those with chronic conditions.

The Academy is pleased that CMS is recognizing that—in addition to primary care providers—cognitive care specialists provide significant amounts of E/M care. The AAN supports a revaluation of E/M care, but shared concerns that any increases in E/M values would also be distributed to surgeons due to global periods associated with many surgical codes. The AAN urged CMS to consider eliminating the global periods and pay for services actually performed and documented.

CMS is expected to issue the final 2012 Physician Fee Schedule rule in early November.