In a comment letter to Centers for Medicare & Medicaid Services (CMS) acting administrator, Andrew Slavitt, regarding the Medicare hospital outpatient prospective payment system (OPPS) proposed rule for 2016 (Proposed Rule), AAHKS focused on four provisions of the Proposed Rule:
• AAHKS thanks CMS for staggering publication of the Proposed Rule and Medicare physician fee schedule proposed rule for CY 2016 (“MPFS Proposed Rule”) and asks that CMS continue to stagger publication of the proposed rules in the future.
• AAHKS urges CMS keep intact the 24 current orthopedic related APCs. To do otherwise will result in inappropriate payment in the outpatient orthopedic setting and decreased beneficiary access to care.
• AAHKS supports CMS’s decision to move more orthopaedic procedures (spine) from the “Inpatient Only” list and recommends that CMS consider eliminating the inpatient only list and letting physicians and patients determine the appropriate site of care.
• AAHKS supports CMS’s decision to create more flexibility in accommodating physician judgment in determining the anticipated length of stays and supports the proposal to shift the review of short inpatient stays from MACs to QIOs so long as CMS requires transparency from the QIOs in the review process.