AAOS’ Specific Recommendations to CMS
In that September 27 letter, AAOS reminded CMS that total joint procedures in an ambulatory surgery center (ASC) are appropriate ONLY for carefully selected patients who are in otherwise excellent health with no or limited medical co-morbidities and sufficient caregiver support.
Those assurances, however, were lacking from CMS’ final rule.
So, President Weber reminded Director Verma of the distinctions between inpatient and outpatient settings and how CMS policies (or lack thereof) would affect total joint arthroplasty patient safety.
Specifically:
- Total joint arthroplasty is a more invasive procedure with a greater risk of complications such as bleeding, deep vein thrombosis and pulmonary embolism than, for example, less invasive hip or knee procedures.
- Best practices for lowering the incidence of total joint arthroplasty adverse events is often available only in the inpatient setting and through use of ancillary services in the postoperative and preoperative periods.
- Only surgeons and physicians have the expertise to determine patient selection for total joint arthroplasty in the ASC setting.
- Not all ASCs or outpatient departments are the same. Surgical site selection must be weighted in light of local conditions and availability of aftercare, home care, transportation and facility capability to treat certain orthopaedic conditions.
- Commercial payers attempts to interpret CMS’ rules to restrict patient access to appropriate care settings on the basis of cost alone.
- Forcing care to an outpatient or ASC setting when not appropriate.
What’s Next?
Since AAOS’ recommendations failed to sway CMS, President Weber is now recommending that “CMS adequately prepare for the effect of these concerning changes. Physicians must be trusted and empowered to designate the best practice setting for their patients, and not be crippled by the burden of proof.”
“Additionally, the statutory requirements of MACRA [Medicare Access and CHIP Reauthorization Act] section 523(a) must be upheld to ensure integrity of the relative value scale and appropriate access to surgical care. We hope that the agency recognizes these impending challenges and is thoughtful about the enforcement of these new policies.”
For more information:
Here are the relevant weblinks to both the CMS ruling and AAOS’ recommendations.
Finally, to lend your voice in support of AAOS’ efforts go to the following website—AAOS advocacy.
