AAHKS Comments on CMS OPPS and ASC Proposed Rule

On July 19, the Centers for Medicare & Medicaid Services (CMS) released the Medicare CY 2022 Hospital Outpatient Prospective Payment System (OPPS) and ASC Payment System Proposed Rule. AAHKS comments included support for hospital-level Risk-Standardized Patient Reported Outcomes Measure Following Elective Primary Total Hip and/or Total Knee Arthroplasty, specifically the inclusion of HOOS Jr. and KOOS Jr. along with PROMIS-Global or VR-12 instruments, as recommended at our 2015 PRO Summit for Total Joint Arthroplasty. Other comments included support for halting the elimination of the IPO list in 2022 and returning to it those procedures that were removed en masse in 2021, though primary THA and TKA are not affected by this proposed change; requesting that CMS create a new exemption from site-of-service claim denials, BFCC–QIO referrals to RACs, and RAC reviews for ‘‘patient status’’ (that is, site-of service, or the 2-midnight rule) for procedures that are removed from the IPO list; and support of the proposal to contract the list of ASC covered surgical procedures, with removal on a case-by-case evaluation, which again does not affect primary THA and TKA. For more information, read our comment letter. We have also signed on to AAOS’s comment letter.