Last week, AAHKS sent our comments to the Centers for Medicare and Medicaid (CMS) on two proposed rules for calendar year 2020. The proposed changes to the CMS Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems included proposals to remove total hip arthroplasty (THA) from the Medicare inpatient only list (IPO), and to add total knee arthroplasty to the ASC covered surgical procedures list. As previously stated in our communications, we concerned that the problems our members faced with the removal of TKA from the IPO have not been fully addressed and therefore it is not likely appropriate for THA to follow at this time. We also requested education and continuing guidance with regard to the TKA IPO removal. For the proposal to add TKA to the ASC list, we appreciated CMS’s note that “a small subset of Medicare beneficiaries” would be appropriate for this sort of care and that it is “imperative that ASCs are adequately prepared to handle the potential needs of this new population.” The letter also notes that the CMS projected reimbursement for the procedure may be too low to provide for its success. Read the full letter for additional information.

AAHKS also provided comments on the Medicare Physician Fee Schedule for Calendar Year 2020 proposed rule. These comments include our concerns regarding the process for nominations of potentially misvalued codes for the AMA RUC process. The letter also touches on office/outpatient evaluation and management (E/M) visit coding and other coding issues. The majority of the letter discusses the questions that CMS presented for input regarding the evolution of MIPS into the MIPS Value Pathways (MVPs). Read the full letter here.