AAHKS Comments on CMS Medicare Advantage and Prescription Drug Proposed Rule

This week AAHKS sent comments to CMS regarding their Contract Year 2024 Policy and Technical Changes to the Medicare Advantage (MA) Program and Medicare Prescription Drug Benefit Program proposed rule. Our comments supported MA coverage and payment criteria that is not more restrictive than Traditional Medicare criteria; requiring MA plans that do not have fully established coverage criteria to use strong guidelines and the highest level of evidence literature to when creating coverage determination policies; as well as supporting the determination of site of service resting solely with the surgeon and patient, based clinical considerations. Further, the letter expresses support for utilization management (UM) committees for MA plans to include a surgeon with specific expertise to the area they are reviewing, such as total joint arthroplasty for our members, as well as gold carding programs to exempt providers for prior authorization. For more information, read the letter.