NANS recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding a proposed payment change that could significantly impact patient access to neuromodulation therapies in ambulatory surgery centers (ASCs).
Under the proposed CY 2027 Outpatient Prospective Payment System rule, CMS would apply multiple-procedure payment reductions to several device-intensive neurostimulation procedures that currently are not subject to those reductions. The affected services include spinal cord stimulation, peripheral nerve stimulation, sacral nerve stimulation, and related implantation and revision procedures.
While multiple-procedure discounts are intended to reflect efficiencies when procedures are performed during the same operative session, NANS is concerned that this approach does not account for the unique cost structure of neuromodulation. Unlike many procedural expenses, the cost of implantable devices does not decrease when multiple components are implanted during a single procedure. Electrodes, pulse generators, and related equipment must still be purchased regardless of how many procedures are performed during one encounter.
If finalized, these payment reductions could make it more difficult for ASCs to continue offering neuromodulation services to Medicare beneficiaries. This could lead to reduced access, longer wait times, increased travel burdens for patients, and a shift of care to higher-cost hospital outpatient settings. NANS is particularly concerned about the impact on patients with chronic pain who have exhausted more conservative treatment options and rely on neuromodulation to improve function and quality of life.
In its comment letter, NANS urges CMS to provide greater transparency regarding the rationale for the proposed changes and to conduct additional analysis before implementing them. Specifically, NANS recommended maintaining the current payment policy for affected neurostimulation procedures until CMS can better evaluate the impact on providers and patients.