The Centers for Medicare and Medicaid Services (CMS) released its proposed payment policy for the Medicare hospital outpatient prospective payment system (OPPS) and ambulatory surgical center (ASC) payment system for calendar year (CY) 2020 on July 29, 2019.

Keep in mind that the American Association of Orthopaedic Surgeons (AAOS) is currently digging through the proposed rule, and AAOS will provide an extensive analysis and comment letter in the near future.

TOA members have been provided an extensive analysis of this proposal. TOA members can either check their e-mail or log into TOA’s website to view the full proposal.

Stakeholder comments are due on September 27, 2019, and you may want to consider making comments on some of these proposals.

Click here to reference the full rule.

Key Concepts
TOA encourages you to read through TOA’s entire summary. In addition, watch for AAOS’s extensive summary.

Some of the key concepts include (these are all proposals):

• • Add TKA to the ASC-payable list. CMS would like comments on what is appropriate for TKA in the ASC setting.
  • Remove THA from the inpatient-only (IPO) list. (This would not necessarily relate in a payable service for ASCs.)
  • Remove additional spine services from the IPO list. (Again, this does not necessarily mean that they would be ASC-payable services in 2020.)
  • Additional guidance related to hospital pricing disclosure. This proposal would have major implications for hospitals. Some of the “shoppable services” would include orthopaedic-related services.
  • Prior authorization for certain non-musculoskeletal services in an attempt to move these services away from the hospital setting. The idea of prior authorization for Medicare services is a controversial topic that Congress addressed (and backed away from) several years ago.
  • Continued payment update parity for ASCs. (Although a less favorable weight scalar of .8452 for ASCs is seen as a negative.)
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