AAOE Submits Comments on 2017 Physician Fee Schedule
Friday, September 2, 2016
Posted by: Bradley Coffey, MA, AAOE Government Affairs
Indianapolis, IN - The American Association of Orthopaedic Executives submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) regarding several of their proposals in the 2017 Physician Fee Schedule. AAOE's comments focused on three provisions of the proposed rule: CMS' proposal to review services that are typically billed with Modifier 25 (indicating significant, separately identifiable evaluation and management service performed) as potentially misvalued, CMS' proposal to require the use of stratified physical and occupational therapy codes, and CMS' proposal to collect data on the resources used in furnishing global surgical packages.
On the global codes proposal, AAOE President Jan Vest, MBA wrote:
AAOE, like other healthcare associations, proudly supported the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) which removed the Medicare Sustainable Growth Rate (SGR) from Medicare payment policy and created the new Merit-based Incentive Payment System (MIPS). We appreciate that CMS is required to collect the global code data under MACRA; however, MACRA requires CMS to collect the information from a “representative sample”. Unfortunately, CMS has decided a representative sample is all relevant providers. We believe CMS’ requirements go well above and beyond Congress’ mandate by requiring every provider submitting a claim for 10- and 90-day global services to submit a CPT code and a new G-code in ten minute intervals for every post-operative follow-up visit.
The AAOE believes that this proposal from CMS will negatively impact patient care and the administration of musculoskeletal practices and strongly urges CMS to revise its proposal to comply with the MACRA statute.
To view AAOE's comments, click here.
Please contact AAOE Government Affairs Manager, Bradley Coffey with any questions regarding this, or any aspect of AAOE's government affairs program.