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News & Press: Government Affairs News

AAOE Submits Stark Comments to CMS and Ways and Means

Monday, August 27, 2018   (0 Comments)
Posted by: Bradley Coffey, MA, AAOE Government Affairs
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Washington, DC - The American Alliance of Orthopaedic Executives (AAOE) submitted comments last week to both the Centers for Medicare and Medicaid Services (CMS) and the House Ways and Means Committee concerning the implementation of the Stark Law and its intersection with value-based payments. 

AAOE's comments focused on the definition of fair-market value under Stark and how definitions subsequent to enactment of the statute have made it difficult for the incentivization of care coordination. In it's letter, AAOE calls for a definition of fair-market value as "any valuation scheme that does not take into account the volume or value of referrals".

AAOE's comments also discuss Stark and participation in multiple payment models and Accountable Care Organizations (ACOs). Currently, CMS uses its Stark waiver authority on a per model basis which causes unnecessary confusion when practices are working to join an alternative payment model or ACO. Instead of engaging in the use of its fraud and abuse waiver authority on a per model basis, AAOE calls on CMS to issue a blanket exemption for providers participating in a two-sided risk model.

Additionally, AAOE addresses calls for repeal of the In-Office Ancillary Services Exception (IOASE) by arguing that the IOASE is necessary to ensure cost savings to the Medicare program. AAOE even broadens the call for maintaining the IOASE and calls on policymakers to allow physicians and practices to own and operate home health agencies (HHAs).


See our comments to CMS here.

See our comments to Ways and Means here.

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