Comment on CMS-2026-2344-0001
Brett SteinwandOpposeOther
Summary: The commenter opposes the proposed cuts to ophthalmic procedure payments, arguing that these reductions threaten the economic viability of Ambulatory Surgical Centers (ASCs). They contend that these procedures are already underfunded and that further cuts will lead to staff shortages and higher costs for patients.
Singling out ophthalmic procedures for cuts simply because they are considered "high volume" is misguided and dangerous. These same procedures have already been decimated on the physician fee schedule over the past 25 years, with many procedures already reimbursing physicians about half of what they did 25 years ago despite skyrocketing costs. The new "efficiency adjustment" is now being layered upon sequestration and years of cuts to the conversion factors and RVUs.
Now, cutting ASC payments rates for the same procedures threatens the viability of ASCs which rely on ophthalmology procedures to be economically viable and provide communities with a lower cost alternative to hospital based surgical care. Staff costs are higher than ever, supply costs are increasing, and OR efficiency is decreasing due to staff shortages and the ever rising complexity of care. Staff who don't get raises due to reimbursement cuts look for work elsewhere. ASCs are already losing money on many glaucoma and retina procedures. Please reconsider these arbitrary and misguided cuts.