AAHKS Comments on CMS Physician Fee Schedule Proposed Rule

On July 23, the Centers for Medicare & Medicaid Services (CMS) released the CY 2022 Physician Fee Schedule Proposed Rule. AAHKS has submitted a comment letter on the Proposed Rule, asking CMS to explain how or why it uses different standards to derive work RVU values from the RUC survey process, develop a new process to account for new non-face-to-face preservice patient optimization time (more than a day before admission and unrelated to initial E/M visits) driven by value-based care arrangements for joint arthroplasty, and recommending CMS provide technical assistance to Congress to waive budget neutrality adjustments for the Physician Fee Schedule Conversion Factor, or otherwise prevent the 3.4% cut in physician payments for hip and knee replacement proposed for 2022, among other issues. Thank you to those members who also submitted comments directly to CMS. For more details on our comments, please read the letter. We have also signed on to AAOS’s comment letter, which you can read here.