AAHKS Submits First CMS MPFS Comment Letter

Due to the magnitude of the Centers for Medicare & Medicaid Services’ (CMS) Medicare Physician Fee Schedule (MPFS) Proposed Rule, AAHKS submitted the first of two planned comment letters this week, ahead of the Sept. 14 deadline. This comment letter centers on the proposed 20% cuts to primary total hip and total knee arthroplasty, and urges CMS to withdraw the proposed drastic RVU reductions to CPT 27130 and 27447. AAHKS states that “it is arbitrary and capricious for CMS to base the work RVUs for total hip replacement and total knee replacement, not upon observed, verified surgeon work time on those procedures, but rather on the work time of the unrelated lap band removal and cornea transplant procedures, respectively. It is also inappropriate for CMS to remove payment for any post-operative surgeon/patient visits in the hospital following these procedures, based not upon the actual number of observed visits occurring, but upon surveys of separate, unrelated procedures and blanket assumptions without factual basis.” If your institution plans to submit comments to CMS on the Proposed Rule, please use the points from our submission. For more detail, read the letter.