Advocacy Action Letters

AAHKS leads the effort to influence the law-making process on matters of hip and knee arthroplasty. These letters, sent to elected officials and government agencies, state our position on issues and provide specific direction to legislation.
Advocacy

November 24, 2020

Bicameral Congressional Letter to CMS regarding Total Joint Arthroplasty Reimbursement Levels for 2021

November 16, 2020

Sign on Letter to Congress in support of H.R. 8702, the Holding Providers Harmless from Medicare Cuts During COVID-19 Act of 2020

October 5, 2020

AAHKS Comment Letter to CMS regarding the CY2021 Physician Fee Schedule Proposed Rule

AAHKS Comment Letter to CMS regarding the CY2021 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems Proposed Rule

AAHKS / EBG Summary of CY 2021 Physician Fee Schedule, Outpatient Prospective Payment System, and Ambulatory Surgical Center Proposed Rules

AAHKS / EBG Final Rule Summaries for 2021 Physician Fee Schedule Physician Fee Schedule; Outpatient Prospective Payment System; and Ambulatory Surgical Center Proposed Rules

September 22, 2020

Sign on Letter to Congressional leaders letter opposing H.R. 884 / S. 2772 – the “Medicare Mental Health Access Act”

August 5, 2020

Sign on Letter to the U.S. President regarding reform to Stark Law and Anti-Kickback Statue regulations

July 29, 2020

Sign on Letter to Congressional Leaders regarding surprise medical billing legislation

July 22, 2020

Sign on Letter to CMS regarding sunsetting scope of practice and licensure waivers following the end of the COVID-19 PHE

July 10, 2020

Comment Letter to CMS regarding Fiscal Year 2021 Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-Term Care Hospital (LTCH) Prospective Payment System and Proposed Policy Changes

AAOS Sign-on letter regarding IPPS proposed rule

July 6, 2020

AAOS Sign on Letter to UnitedHealthcare regarding new commercial medical policy imaging requirements

July 1, 2020

Sign on Letter to HHS requesting implementation of RUC recommended values for office and outpatient visits

June 24, 2020

Sign on Letter to the U.S. Department of Veterans Affairs with AMA regarding scope of practice for CRNAs

June 22, 2020

Congressional Letter to CMS regarding Total Joint Arthroplasty Reimbursement Levels for 2021

Comment letter to CMS regarding the Comprehensive Care for Joint Replacement (CJR) Model Three-Year Extension and Changes to Episode Definition and Pricing

AAOS Sign on Letter regarding CJR Model Three-Year Extension and Changes to Episode Definition and Pricing

June 9, 2020

Sign on Letter with AMA to Congressional leaders regarding support for the targeted and limited liability protections included in the bipartisan bill, H.R. 7059, the “Coronavirus Provider Protection Act”

June 1, 2020

Comment letter to CMS regarding the first Interim Final Rule for flexibilities for responding to the COVID-19 public health emergency

May 27, 2020

CMS Medicare IPPS Proposed Rule Summary

CMS COVID-19 Second Interim Final Rule Summary

April 15, 2020

Sign on letter with AMA to Congressional leaders regarding potential issues to be addressed in a “phase four” COVID-19 relief package

April 10, 2020

Sign on letter with AAOS to Congressional leaders urging inclusion of orthopaedic priorities in the fourth COVID-19 legislative package

April 7, 2020

Sign on letter with AMA to HHS Secretary Azar requesting immediate financial assistance for physicians

March 30, 2020

Sign on letter with AAOS to CMS Administrator Verma requesting CMS accept the RUC-recommended values for E/M global codes for CY 2021, including surgical codes

March 26, 2020

Sign on letter with AAOS to U.S. Vice President Pence requesting guidance and framework for PPE, emergency surgery and post-pandemic considerations

March 25, 2020

Sign on letter coordinated by AMA to Congressional leaders to seek support for physicians in any and all Congressional stimulus packages during the COVID-19 outbreak

March 20, 2020

Letter to CMS Administrator Verma regarding CMS Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly (CMS-4190-P) Proposed Rule – Sign on with AAOS

December 31, 2019

Comment letter to Centers for Medicare & Medicaid Services (CMS) regarding Modernizing and Clarifying the Physician Self-Referral law (Stark law)

November 20, 2019

Response to Centers for Medicare & Medicaid Services (CMS) Center for Program Integrity Request for Information: The Future of Program Integrity

October 29, 2019

Sign On Letter with the AMA to HHS Secretary regarding supervision and reimbursement of nonphysicians in the October 3, 2019 Executive Order entitled, “Protecting and Improving Medicare for our Nation’s Seniors”

October 16, 2019

Senate Surprise Billing Sign On Letter with AMA

House of Representatives Surprise Billing Sign On Letter with AMA

September 27, 2019 Comment Letter to CMS

Centers for Medicare & Medicaid Services (CMS) Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems Proposed Rule for Calendar Year 2020

Summary of the OPPS and ASC Final Rule

September 27, 2019 Comment Letter to CMS

Centers for Medicare & Medicaid Services (CMS) Medicare Physician Fee Schedule (PFS) Proposed Rule for Fiscal Year 2020

Summary of PFS Final Rule

September 19, 2019 Letter to CMS

Sign on Letter to CMS Regarding Automation of Prior Authorization

September 9, 2019 Letter to Congress

Sign on letter to Congress in support of the Improving Seniors’ Timely Access to Care Act of 2019 (H.R. 3107)

August 15, 2019 Comment Letter to CMS

Sign on letter with American College of Surgeons regarding adjusted values for revised E/M codes in the 2020 Medicare Physician Fee Schedule proposed rule

August 12, 2019 CMS Request For Information 

Centers for Medicare & Medicare Services RFI: Reducing Administrative Burden to Put Patients over Paperwork

AAOS RFI Sign On Letter

July 16, 2019 Letter to House Committee on Energy and Commerce

Letter to Chairman and Ranking Member of the House of Representatives Committee on Energy and Commerce regarding Surprise Billing and the need for an independent dispute resolution (IDR) process – Sign on with AMA

June 24, 2019 Comment Letter to CMS

Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2020 Rates

AAOS IPPS Sign On Letter

May 21, 2019 Letter to CMS Administrator 

Letter to CMS Administrator Verma in support of CMMI demonstration model allowing for expansion of physician owned hospital facilities

April 10, 2019 Co-sponser Letter to Congress

Letter to Congress, encouraging them to co-sponsor the “The Resident Physician Shortage Reduction Act of 2019” (S. 348, H.R. 1763)

April 1, 2019 Comment Letter to CMS

Administration Simplification: Modification of the Requirements for the Use of HIPAA National Council for Prescription Drug Programs (“NCPDP”) D.0 Standard

February 7, 2019 Letter to House Committee on Ways and Means

Surprise patient billing letter urging accountability and transparency in Congressional bills Sign on with AMA

January 28, 2019 Comment Letter to CMS

HHS Office for the National Coordinator (ONC) for Health IT Draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs Sign on with AAOS

January 15, 2019 Comment Letter to CMS

CMMI Bundled Payment for Care Improvement (BPCI) Advanced Addendum Sign on with AAOS

January 4, 2019 Comment Letter to CMS

CMS & Yale CORE Draft MIPS Measure Methodology Report for Public Comment: Clinician and Clinician Group Risk-Standardized Complication Rate Following Elective Primary Total Hip Arthroplasty and/or Total Knee Arthroplasty

September 24, 2018 Comment Letters to CMS
Medicare Program: CY 2019 Proposed Changes to the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems

September 10, 2019 Comment Letters to CMS
Medicare Program: Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for FY 2019; Quality Payment Program; and Medicaid Promoting Interoperability Program

August 27, 2018 Comment Letter to CMS
Medicare Physician Fee Schedule for CY 2019 – Excessive E/M Documentation – Sign on with the American Medical Association

August 15, 2018 Comment Letter to House of Representatives Health Care Innovation Caucus

June 25, 2018 Comment Letter to CMS

May 10, 2018 Letter to National Council of State Boards of Nursing 
National Council of State Boards of Nursing Provisions of the Advanced Practice Registered Nurse Compact that alter state laws related to APRN scope of practice

March 21, 2018 Comment Letter to CMS Administrator Seema Verma
Removal of Total Knee Arthroplasty From the Medicare Inpatient Only List

February 21, 2018 Comment Letter to CMS
Bundled Payment for Care Improvement (BPCI) Advanced Request for Application Comment Sign on with AAOS

November 20, 2017 Comment Letter to CMS
Center for Medicare & Medicaid Innovation (CMMI) New Direction Request for Information

November 20, 2017 Comment Letter to CMS and Acumen, LLC
MACRA Episode-Based Cost Measures Field Testing, Total Knee Arthroplasty Measure – AAHKS and The Knee Society Sign On

October 16, 2017 Comment Letters to CMS
CMS-5524-P: Medicare Program; Cancellation of Advancing Care Coordination Through Episode Payment and Cardiac Rehabilitation Incentive Payment Models; Changes to Comprehensive Care for Joint Replacement Payment Model

September 11, 2017 Comment Letter to CMS

September 11, 2017 Comment Letter to CMS
CY 2018 Medicare Physician Fee Schedule Proposed Rule

August 25, 2017 Submission to the House of Representatives Committee on Ways and Means, Subcommittee on Health
Medicare Red Tape Relief Project Submissions

August 21, 2017 Comment Letter to CMS

June 13, 2017 Comment Letter to CMS

June 7, 2017 Endorsement Letter
Letter supporting the introduction of “Increasing Access to Osteoporosis Testing for Medicare Beneficiaries Act of 2017″ in Congress – Sign-on with AAOS

March 21, 2017 Comment Letter to CMS
Letter requesting easing of penalties for physicians in the area of PQRS, MU and Value based Payment Modifier, in MIPS reporting under MACRA – Sign-on with AMA

February 27, 2017 Letter to CMS and ONC
Letter requesting deferment from implementing 2015 Edition certified electronic health record technology (CEHRT) – Sign-on with AMA

February 1, 2017 Letter of Support to the Senate Finance Committee
AAHKS Letter of Support for the nomination of Dr. Tom Price as HHS Secretary

January 6, 2017
CMS Medicare Quality Payment Program Patient Relationship Categories and Codes Comment Letter

October 3, 2016 Comment Letter to CMS
CMS–5519–P: Advancing Care Coordination through Episode Payment Models (EPMs); Cardiac Rehabilitation Incentive Payment Model; and Changes to the Comprehensive Care for Joint Replacement Model (CJR)

September 6, 2016 Comment Letter to CMS
CY 2017 Medicare Physician Fee Schedule Proposed Rule

September 6, 2016 Comment Letter to CMS
CY 2017 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Proposed Rule

August 24, 2016 Comment Letters to AHRQ
Draft manuscript entitled “Comparative Effective Review: Venous Thromboembolism Prophylaxis in Major Orthopaedic Surgery: Systematic Review Update”

August 23, 2016 Letter to CMS
Recommending CMS restore the Refinement Panel to serve as the relative value appeals process – Sign-on with AMA

August 11, 2016 Endorsement Letter to Speaker Ryan
Support of 21st Century Cures Bill – Sign-on with AMA

July 22, 2016 Comment Letter to David J. Shulkin, MD, Under Secretary for Health, Department of Veterans Affairs
RIN 2900–AP44-Advanced Practice Registered Nurses; Proposed Rule – Sign-on with AMA

July 11, 2016 Comment Letter to Representatives Ellmers and DeGette
H.R. 1221, the Helping Ensure Life- and Limb-Saving Access to Podiatric Physicians (HELLPP) Act – Sign-on with AAOS

June 29, 2016 Endorsement Letter to Senator Barrasso
S. 2978, the Protect Continuing Physician Education and Patient Care Act – Sign-on with AMA

June 27, 2016 Comment Letters to CMS 
Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models; Proposed Rule (CMS-5517-P)

June 17, 2016 Comment Letter to CMS
FY 2017 Hospital Inpatient Prospective Payment Systems Proposed Rule

June 7, 2016 Endorsement Letter to Senators Blunt and Reed; Congressmen Collins and Courtney
H.R. 1859/S. 2782, the Ensuring Children’s Access to Specialty Care Act – Sign-on

June 3, 2016 Comment Letter to ONC
Request for Information regarding Assessing Interoperability for MACRA – sign-on with AAOS

May 20, 2016 Open Letter to NIH
Review and Funding of Clinically Impactful Research Grants – sign-on with AAOS

March 29, 2016 Comment Letter to CMS
Medicare Program: Expanding Uses of Medicare Data by Qualified Entities

March 28, 2016 Comment Letter to the Health Care Payment Learning & Action Network (LAN)
Accelerating and Aligning Clinical Episode Payment Models: Elective Joint Replacement draft white paper

March 1, 2016 Comment Letter to CMS
Quality Measure Development Plan: Supporting the Transition to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs)

November 17, 2015 Comment letter to CMS
Merit-Based Incentive Payment System and Alternative Payment Models under the new Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

November 2, 2015 Letter to U.S. Senate
Stage 3 of the Meaningful Use Program

September 21, 2015 Letter to CMS from Congressman Tom Price, MD
Comprehensive Care for Joint Replacement Payment Model

September 8, 2015 Comment letter to CMS
Comprehensive Care for Joint Replacement Payment Model

August 7, 2015 Comment letter to National Government Services, Inc.
Draft LCD DL36039 — Total Joint Arthroplasty (Jurisdiction 6 and Jurisdiction K)

June 17, 2015 Joint letter to House Committee on Energy and Commerce
Support and comments on the 21st Century Cures initiative

June 15, 2015 Letter to US Representative Diane Black
Support for H.R. 2247 “Increasing Clarity for Doctors by Transitioning Effectively Now Act” (ICD-TEN Act)

June 15, 2015 Comment letter to CMS
Medicare Program: Hospital Inpatient Prospective Payment System Proposed Rule for FY 2016 (CMS-1632-P)

May 29, 2015 Comment letter to CMS
CMS-3310-P Medicare and Medicaid Programs; Electronic Health Record Incentive Program – Stage 3

May 6, 2015 Letter to Congress
Repeal of IPAB

April 27, 2015 – Comment letter to CMS Deputy Administrator for Innovation & Quality
AAMC recommendation to create a new DRG for hip fractures.

March 30, 2015 – Comment letter to CMS
The development of a measure for risk adjusted improvement in functional status after total hip and knee replacement.

March 16, 2015 – Multi-Specialty Letter to House Speaker, John A. Boehner
Repeal of failed SGR before the expiration of the current payment patch.

March 4, 2015 – Comment letter to CMS/HHS
ICD-10 requirement starting October 1, 2015

November 20, 2014 – Comment letter to Yale New Haven Health Services Corporation and the Center for Outcomes Research and Evaluation (CORE) for CMS
Development of Measures of Payment for Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA)

November 6, 2014 – Comment letter to Novitas Solutions, Inc.
Draft LCD – Lower Extremity Major Joint Replacement (Hip and Knee), DL35594 (Jurisdictions H & L)

October 17, 2014 – Comment letter to Medicare Payment Advisory Commission (MedPAC)
Validating relative value units (RVU) in the Medicare physician fee schedule (MPFS)

August 28, 2014 – Comment letter to CMS
Medicare Payment Policies under the Proposed Physician Fee Schedule for CY 2015 [CMS-1612-P]

June 27, 2014 – Comment letter to CMS
Medicare Hospital Inpatient Prospective Payment Proposed Rule for FY2015 (CMS-1607-P)

January 9, 2014 – Comment letter to CMS
CMS 1600-FC, Medicare Physician Fee Schedule for CY 2014: Interim Hip and Knee Replacement RVUs