In the last week AAHKS has commented on the Centers for Medicare & Medicaid Services’ (CMS) Medicare Physician Fee Schedule (PFS) and Medicare Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs (OPPS) proposed rules for calendar year 2026. For the PFS proposed rule, AAHKS comments stated that the rule contains a series of arbitrary proposals, not based on empiric data, that will lead to less accurate RVUs and will accelerate provider consolidation; the Conversion Factor increases are insufficient to reverse falling reimbursements; and Congress and CMS should enact physician payment reforms and account for inflation by adjusting physician payments to the Medicare Economic Index, among many others.
The OPPS proposed rule comments included supporting maintaining the IPO list in 2026 and removing procedures from the IPO list over time after all regulatory criteria have been satisfied; support for a new APC for outpatient TJA procedures with revisions needing to be valued higher than primaries; support for a period of exemption from RAC audits for any procedures removed from the IPO and noting rising administrative burdens for procedures removed from the IPO; the need for physician inflationary updates to match the CMS proposals for increased institutional payment rates; and disagreeing with CMS’ presumption that relative prices paid by either MA plans or other commercial insurers would be a better reflection of hospitals’ true relative costs across DRGs than the current system of using cost report data to estimate relative costs. For more, read our PFS Comment Letter and OPPS Comment Letter. AAHKS will also send an Action Alert soon, urging all members to write their Congressional representatives about these issues.
