ASA Comments on CMS's Proposed Rule for the CY2021 Outpatient Prospective Payment System

In comments to the Centers for Medicare & Medicaid Services (CMS), ASA provided feedback to CMS on two issues included in CMS’s Proposed Rule for the CY2021 Outpatient Prospective Payment System (OPPS). In our letter, ASA cautions CMS against moving too expeditiously on expanding its prior authorization program to include implanted spinal neurostimulators. ASA urges the agency to carefully consider any action that could hinder access to non-opioid alternatives to pain medicine. This CMS Prior Authorization program was first implemented in July 2020 so meaningful and actionable data on its impact on patient care and it affect on utilization are not yet available.