The organizations recommend CMS maintain its proposed rates for stereotactic radiosurgery from the Notice of Proposed Rulemaking published earlier this year in the Federal Register. The letter also suggests reviewing data and methodology used for setting SRS payment rates and publishing the results for public comment on future rulemaking.
The letter also addresses bundling of services, urging CMS not to implement a new proposal that it believes would penalize hospitals for providing same day services. The proposal includes new categories for hospital Outpatient Prospective Payment System items and establishes new comprehensive Ambulatory Payment Classifications for device-dependent services that would issue one payment for services billed on the same day whereas now there are certain situations where more than one APC payment may have been allowed.
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