The American Association of Orthopaedic Surgeons has issued formal comments to CMS on the agency's proposed payment policy changes for 2022.
The association focused its comments on two key changes proposed — reversing the elimination of the inpatient-only list and pulling back the 298 procedures, including 266 musculoskeletal procedures that were removed from the list on Jan. 1.
In a letter to CMS Administrator Chiquita Brooks-LaSure, the association urged the agency not to make "such wide swings in complicated policy decisions within short time periods," instead making them in a gradual, transparent manner to allow stakeholders adequate time to prepare.
"When musculoskeletal procedures were identified as the first group to be eliminated from the IPO List, CMS would have benefited from a consultative effort with orthopedic surgeons to determine the suitability of specific procedures, the impact on Medicare beneficiaries and on the delivery of healthcare services," said association President Daniel Guy, MD. "With further review, CMS has taken a step back, as unintended consequences have become apparent. The AAOS is ready to be an important resource to assist CMS in making the best decisions for patients and their care."
The association stated that some musculoskeletal procedures can safely be done in the outpatient setting and reiterated that criteria for surgery should be based on peer-reviewed evidence, patient factors such as age, comorbidities and social support, and decided by physicians through the lens of patient safety.
With regard to proposed cuts to Medicare's physician fee schedule, Dr. Guy urged CMS to "maintain the current funding levels" which is "critical to preserving access to patient care during the COVID-19 public health emergency."
CMS proposed to decrease the conversion factor by 3.75 percent and did not incorporate the office/outpatient evaluation and management code updates into the global surgical codes.
The association also urged CMS to permanently maintain the flexibilities for telehealth services offered during the COVID-19 pandemic, which have helped limit exposure for susceptible patients with in-person visits.
The association also asked that the Appropriate Use Criteria program for advanced diagnostic imaging be delayed indefinitely, based on concerns that it would detract from the development of the Quality Payment Program.