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

December 11

Sign on letter in support of the White House Initiative on Women’s Health Research

November 16

Sign on letter to Congressional leaders urging Congress to pass legislation to avert impending Medicare cuts for 2024

November 6

Sign on letter to Congressional leaders urging Congress to stop the 3.4% cut in Medicare physician payment, finalized in the CMS CY2024 Physician Fee Schedule Final Rule

October 31

Sign on letter to Congressional leaders regarding drafting a proposal to reform Medicare budget-neutrality policies

October 4

Sign on letters to Congressional leaders urging them to halt the implementation of Healthcare Common Procedure Coding Systems add-on code G2211 House Letter | Senate Letter

September 11

AAHKS Summaries of the CMS 2024 Medicare Final Payment Rules: Physician Fee Schedule; Outpatient Prospective Payment System; and Ambulatory Surgical Centers

Comment Letter to CMS on FY2024 Medicare Physician Fee Schedule (PFS) Proposed Rule

Comment Letter to CMS on FY2024 Medicare Hospital Outpatient Prospective Payment System (OPPS) Proposed Rule

AAHKS Summary of CY 2024 Medicare Physician Fee Schedule (PFS) and Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS & ASC) Proposed Rules

Sign on letter to CMS Regarding Coverage for Fracture Liaison Services with the Bone Health and Osteoporosis Foundation (BHOF) and the American Society for Bone and Mineral Research (ASBMR)

August 17

CMS Innovation Center Request For Information on Episode-Based Payment Models

June 13

Open Letter coalition sign on with AOSSM regarding team physician expert witness testimony

June 9

Comment Letter to CMS on 2024 Medicare Inpatient Prospective Payment System Proposed Rule

April 19

Comment Letter to FTC on proposed rule “Non-Compete Clause Rulemaking, Matter No. P201200”

April 14

Comment Letter with American Society for Bone and Mineral Research (ASBMR) and the Bone Health and Osteoporosis Foundation (BHOF) to CMS Regarding establishing a care coordination payment mechanism for secondary prevention of osteoporotic fractures

March 15

Comment Letter with AMA to Congress Regarding Legislation for Annual Inflation-Based Payment Update

March 13

Comment Letter to CMS on proposed rule “Administrative Simplification: Adoption of Standards for Health Care Attachments Transactions and Electronic Signatures, and Modification to Referral Certification and Authorization Transaction Standard”

February 14

Comment Letter to CMS Regarding the 2024 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs

January 23

Coalition Letter to Congress Regarding Reforming the Medicare Payment System

January 5

Federal Trade Commission Summary of Proposed Rule to Eliminate Non-Compete Clauses

December 8, 2022

Letter to Congressional Leadership Urging Extension of 5% Medicare APM Incentive Payment

December 5, 2022

Coalition Sign On Letter to Congressional Leadership Regarding Medicare Physician Payment

November 28, 2022

Medicare Physician Fee Schedule and Outpatient Prospective Payment System & Ambulatory Surgical Centers Final Rule Summaries

September 30, 2022

AAHKS Comment Letter to CMS Regarding Development of a Hospital-Level 90-Day Risk-Standardized Complication Rate (RSCR) Following Elective Primary THA and/or TKA for a Combined Inpatient and Outpatient Setting Measure

September 22, 2022

Sign On Letter with AMA to Congressional Leadership Regarding Medicare Physician Payment

September 13, 2022

AAHKS Comment Letter to CMS regarding the CY2023 Medicare Outpatient Prospective Payment System and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs (OPPS) Proposed Rule

Sign On Letter with AAOS to CMS Regarding CY2023 Medicare OPPS Proposed Rule

AAHKS Summary of CMS CY2023 Medicare Outpatient Prospective Payment System (OPPS) Proposed Rule including the Ambulatory Surgical Center (ASC) Payment System

September 6, 2022

AAHKS Comment Letter to CMS regarding the CY2023 Medicare Physician Fee Schedule Proposed Rule

Sign on Letter with AAOS to CMS regarding CY2023 Physician Fee Scheduleand Ambulatory Surgical Center Payment Systems and Quality Reporting Programs

AAHKS Summary of CMS CY2023 Physician Fee Schedule Proposed Rule

August 31, 2022

Centers for Medicare & Medicaid Services (CMS) on its Request for Information (RFI) on the Medicare Advantage (MA) program

June 17, 2022

Comment Letter to CMS regarding the 2023 Medicare Inpatient Prospective Payment System (IPPS) Proposed Rule

Sign on Letter with AAOS to CMS regarding the 2023 IPPS Proposed Rule

CMS CY2023 IPPS Final Rule Summary

June 1, 2022

Comments to the National Committee for Quality Assurance (NCQA) on maintenance of total hip and total knee arthroplasty electronic clinical quality measures (eCQMs)

April 19, 2022

Sign on letters with the Arthritis Foundation seeking CDC funding for arthritis programming in the Congressional Fiscal Year 2023 Labor, Health and Human Services, and Education Appropriations bills: Senate Letter | House Letter

March 24, 2022

HHS Office of the National Coordinator for Health IT (ONC) RFI: “Electronic Prior Authorization Standards, Implementation Specifications, and Certification”

February 2, 2022

Sign on letter with AAOS to CMS regarding concers with the National Correct Coding Initiative (NCCI) Medically Unlikely Edit (MUE) and Procedure-to-Procedure Edit (PTP) programs

December 3, 2021

Sign on Letter with AAOS to CMS regarding the Requirements Related to Surprise Billing; Part II Interim Final Rule

November 29, 2021

Congressional Coalition Letter Seeking Medicare Payment Stability through CY 2022

November 17, 2021

Comment letter on proposed CMS Clinician-Level and Clinician Group-Level Total Hip Arthroplasty and/or Total Knee Arthroplasty (THA and TKA) Patient-Reported Outcome-Based Performance Measure (PRO-PM)

November 4, 2021

Summary of the CMS CY 2022 Medicare Physician Fee Schedule (PFS) final rule and Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS & ASC) final rule

October 14, 2021

Congressional letter urging CMS to avert payment cuts to physicians and develop long-term reform to the Medicare payment system

September 17, 2021

Comment Letter to CMS regarding the 2022 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems Proposed Rule

Sign on Letter with AAOS to CMS regarding the 2022 OPPS and ASC Proposed Rule

September 13, 2021

Comment Letter to CMS regarding the 2022 Medicare Physician Fee Schedule Proposed Rule

Sign on Letter with AAOS to CMS regarding the 2022 Medicare Physician Fee Schedule Proposed Rule

July 28, 2021

Summary of the Proposed 2022 Medicare Payment Rules: Physician Fee Schedule; Outpatient Prospective Payment System and Ambulatory Surgical Centers

June 28, 2021

Comment Letter to CMS regarding the 2022 Medicare Inpatient Prospective Payment System (IPPS) Proposed Rule

Sign on Letter with AAOS to CMS regarding the 2022 IPPS Proposed Rule

Summary of CMS CY2022 Medicare Inpatient Prospective Payment System (IPPS) Proposed Rule

April 29, 2021

Summary of CJR Final Rule Extending Model for 3 Performance Years

April 27, 2021

Sign on letter to Congress to Fund “Health Care Infrastruture” through 2021

April 21, 2021

Sign on letter to Congress for funding of CDC Arthritis Program

March 10, 2021

Sign on letter to HHS and CMS provideing guidance for rulemaking on surprise billing in the No Surprises Act of 2020

January 4, 2021

Comment Letter to CMS regarding CMS–9912–IFC – Additional Policy and Regulatory Revisions in Response to the COVID–19 Public Health Emergency – Comprehensive Care for Joint Replacement (CJR) Model

Summary of CMS Interim Final Rule for Additional Policy and Regulatory Revisions in Response to the COVID–19 Public Health Emergency – Comprehensive Care for Joint Replacement (CJR) Model

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

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