AAOS March 20, 2018
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AAOS Send Letter to CMS on TKA Issues

Until recently, total knee arthroplasty (TKA) was included on the Medicare inpatient-only (IPO) list. In light of the removal of TKA from the IPO, AAOS produced a FAQ and other resource documents available on the AAOS website, here. However, AAOS also recently sent a letter to the Centers for Medicare & Medicaid Services (CMS) expressing concern over interpretation of the new rule.

“One of the unintended consequence of this policy change has been a lot of confusion on the part of a variety of stakeholders regarding how to interpret this new rule,” the letter states. “Hospitals, surgeons, and payers are interpreting the rule from different perspectives and have been sharing differing guidance. The hospital or Medicare Advantage plan directing the site of service decision over the operating surgeon’s discretion is also in contradiction to CMS’ intent in the final rule. Specifically, CMS points to the beneficiary’s physician as the medical professional responsible for determining the care setting in this rule. We are concerned that unqualified decision-making on the site of service will harm Medicare beneficiaries…”  

In the letter, AAOS notes that it is our understanding the IPO list status of a procedure has no effect on the Medicare Physician Fee Schedule (MPFS) professional payment for the procedure. Physicians will continue to be paid the same regardless of the site of service. We also understand that the facility payment under the OPPS will be lower than under the inpatient Medicare Severity Diagnosis Related Group (MS-DRG) system. However, the letter explains that many physicians have been advised by their hospitals, plans, or compliance experts that their reimbursements may be affected by this change in policy. While AAOS has provided updates on this, we argue that a more definitive guidance from CMS in this regard would be helpful for all stakeholders.

Read the letter online here. For additional questions related to this issue, please contact Dena McDonough, Manager of Payment Policy at mcdonough@aaos.org.