Comment on CMS-2026-1256-0002
International Society for the Advancement of Spine SurgeryOtherAdvocacy
Summary: The International Society for Advancement of Spine Surgery (ISASS) submitted a mixed-stance comment regarding the proposed rule. They support the creation of new MS-DRGs for complex spinal fusion procedures but oppose the repeal of the Breakthrough Device Designation Pathway to NTAP and advocate for allowing physician-owned hospitals to participate in the TEAM bundled payment model.
The International Society for Advancement of Spine Surgery (ISASS), which is dedicated to advancing major evolutionary steps in spine surgery, appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) FY2027 Hospital Inpatient PPS Proposed Rule.
The attached letter includes our recommendations and comments regarding the following proposals included in the rule:
•The creation of new MS-DRGs to better classify extensive and complex spinal fusion procedures involving significant deformity correction and/or multilevel thoracolumbar reconstruction, and inclusion of these new MS-DRGs within the Transforming Episode Accountability Model (TEAM) spinal fusion episode category
•Repeal of the Breakthrough Device Designation Pathway to NTAP
•Allowing physician-owned hospitals to participate in the TEAM bundled payment model by removing Section 6001-based restrictions that exclude or disadvantage physician-owned hospitals in value-based payment programs.