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News & Press: Government Affairs News

CMS Finalizes Addition of TKAs to ASC List

Monday, November 4, 2019   (0 Comments)
Posted by: Brad Coffey, MA, O-CHCP, AAOE Government Affairs
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Baltimore, MD - The Centers for Medicare and Medicaid Services (CMS), have finalized the addition of total knee arthroplasty, 27447 (Arthroplasty, knee, condyle and plateu; medial and lateral compartments with or without patella resurfacing (total knee arthroplasty)) to the Ambulatory Surgery Center Covered Procedures List for CY 2020. The addition of this procedure to the ASC Covered Procedures List means that this procedure may now be performed in an ASC for eligible Medicare beneficiaries.

CMS first proposed this change in 2018 but did not finalize the proposal due to concern from commenters that ASCs were not equipped to safely perform TKA procedures on Medicare beneficiaries. In the CY 2020 Outpatient Prospective Payment System final rule, released November 1, 2019, CMS agreed with commenters that there is a small subset of Medicare beneficiaries who may be suitable for outpatient TKAs performed in an ASC setting.

CMS does not expect this to lead to a groundswell of TKAs being moved to the ASC setting. Indeed, in a response to a commenter who was concerned about the potential negative effects of moving healthy patients to sites of service that are ineligible for BPCI Advanced or CJR, CMS wrote that "... there are a small number of less medically complex TKA patients that could appropriately receive TKA in an ASC setting. Because we believe this group will be small, we do not believe our proposal would have a substantial impact on the patient-mix for the Bundled Payments for Care Improvement Advanced (BPCI Advanced) or the Initiative and Comprehensive Care for Joint Replacement (CJR) models. Therefore, we do not believe any delay in the implementation of our proposed addition to the ASC Covered Procedures List is warranted." In 2016, TKAs performed in an ASC setting made up 0.002% of the total volume of knee replacements performed in the Medicare Advantage program. Were this to hold true for Traditional Medicare as well, we could expect to see approximately 1,182 TKAs performed in an ASC on Traditional Medicare beneficiaries.

CMS did not finalize any additional requirements that had been proposed such as adding a modifier or requiring an ASC to have a certain amount of experience in performing a procedure before being eligible for payment. Physicians should continue to screen patients carefully if they are considering them for surgery in an ASC. CMS states that ASC TKA procedures should only be performed on patients who are not expected to require active medical monitoring and care of the beneficiary at midnight following the procedure.

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