Advocacy & Practice Updates — Advocacy & Practice

ASRS Recommends CMS Rethink Office-based Retina Surgery, Increase Global Surgery Post-Op Visit Values in Proposed Rule Comments

This week, ASRS submitted comments on the 2023 Medicare Physician Fee Schedule proposed rule. In our letter, we oppose a request by an outside vendor to develop facility practice expense values for office-based retinal surgery on the grounds that there is no clinical data establishing its safety and we are not aware of any demand to move procedures from ASCs or outpatient departments to the office setting.

In response to CMS’ request for information on global surgery codes, we reiterate our long-held position that the value of post-operative visit codes included in 10- and 90-day global codes should be increased to align with the 2021 increase of standalone E/M codes. In addition, we request an exemption for small volume ophthalmic drugs from the drug wastage provisions of the proposed rule and ask for detailed guidance for physicians on how to report on potentially unused volume of Part B drugs furnished in single-use vials.

ASRS also submitted joint comments on the proposed rule with the Alliance of Specialty Medicine and the Surgical Coalition. The final rule is expected to be released in November.