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Alliance Comments on Alzheimer’s Disease Diagnostics, Glaucoma in Medicare Outpatient Rule

Published September 13, 2022

The Alliance submitted comments on the calendar year (CY) 2023 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS) proposed rule and encouraged key changes to ensure patients’ access to needed care. The Alliance’s letter to the Centers for Medicare and Medicaid Services (CMS) included the following recommendations:

  • Ensure that reimbursement for minimally-invasive procedures for glaucoma in the hospital setting reflects the cost of treatment. In the proposed rule, CMS recommended classifying such procedures in a payment category that would result in physicians and facilities losing money on each procedure performed. The Alliance asked the agency to follow the recommendation of Medicare’s expert panel on outpatient payment, who recommended that the procedure be reclassified to a higher payment category. This change would ensure appropriate payment and enable patients to access these treatments.
  • Decouple payment for radiopharmaceuticals necessary for beta amyloid positron emission tomography (PET) scans needed to determine if a beneficiary has Alzheimer’s disease. Currently, payment for amyloid and tau PET tracers occurs within the payment for the diagnostic. However, including the additional cost of the tracers results in the existing payment for PET scan results in costs exceeding the reimbursement provided by Medicare. As a result of this payment policy, many hospital sites no longer participate in clinical trials that are attempting to accumulate additional data on the impacts of the procedure on diverse populations. Decoupling payment for amyloid and tau tracers would ensure that providers are able to cover the cost of care and that patients have access to these needed diagnostic tests.

The Alliance’s comments on the Ambulatory Surgical Center/Hospital Outpatient Prospective System can be read here.

The Alliance for Aging Research is the leading nonprofit organization dedicated to accelerating the pace of scientific discoveries and their application to vastly improve the universal human experience of aging and health. The Alliance believes advances in research help people live longer, happier, more productive lives and reduce healthcare costs over the long term. For more than 35 years, the Alliance has guided efforts to substantially increase funding and focus for aging at the National Institutes of Health and Food and Drug Administration; built influential coalitions to guide groundbreaking regulatory improvements for age-related diseases; and created award-winning, high-impact educational materials to improve the health and well-being of older adults and their family caregivers. For more information, visit

For more information about the Alliance for Aging Research or to interview an expert on this topic, please contact Katie Riley, Vice President of Communications, at [email protected].