Comment on CMS-2026-1256-0002
Epilepsy Foundation of AmericaOpposeAdvocacy
Summary: The Epilepsy Foundation of America opposes the proposed repeal of the alternative pathway for new technology add-on payments (NTAP) and the elimination of hospital outpatient prospective payment system (OPPS) device pass-through payments. They argue these changes will create significant reimbursement barriers for innovative epilepsy therapies, making it difficult to meet "Substantial Clinical Improvement" standards and potentially disincentivizing future research and development.
Please see the attached comments from the Epilepsy Foundation of America (EFA).