REGULATORY REVIEW
Joint Replacement Front and Center in OPPS/ASC Proposed Rule CMS seeks feedback on the potential for adding TKA, PHA and THA to the ASC-payable list BY KARA NEWBURY
Advances in medical tech- nology have expanded the types of patients who can be treated outside the hospital. Despite these
advances, the Centers for Medicare & Medicaid Services’ (CMS) pay- ment policies have traditionally lagged innovation, and many procedures, such as total joints, are currently on the inpatient-only (IPO) list. Promising, though, is CMS’ recent proposal to remove total knee arthroplasty (TKA), code 27447, from the IPO list for 2018. The agency also is requesting feed- back on the potential removal of total hip arthroplasty (THA) and partial hip arthroplasty (PHA) from the IPO list. For these procedures to migrate to the ASC setting, however, the industry will need to pursue changes to regula- tions that currently serve as roadblocks and continue to provide supporting data proving what it already knows: these procedures are being done safely and effectively in the ASC setting at a lower cost to payers and patients.
Background
CMS first proposed removing TKA from the IPO list five years ago, in the 2013 Outpatient Prospective Payment System/ASC Payment System Pro- posed Rule. At that time, there were 76 comments addressing the proposal, and only two of those were supportive. Many of the others were negative, even accusing CMS of supporting malprac- tice by even proposing to allow TKA to be done in an outpatient setting. Over the past few years, ASCA has
worked hard to change this percep- tion, as our members have increasingly been performing these procedures safely and effectively on the non- Medicare population. Even though
In addition to removing TKA from the IPO list, CMS also is requesting comments on whether PHA, CPT code 27125, and THA, CPT code 27130, should be removed from the IPO list.”
—Kara Newbury, ASCA
codes are rarely taken off the IPO list and put directly onto the ASC-pay- able list, ASCA views this as a long- term initiative, and the first step to ASC reimbursement is reimbursement in the hospital outpatient department (HOPD) setting. ASCA has taken mul- tiple orthopedic surgeons to meet with CMS and review their stellar outcomes data in the outpatient setting. These efforts resulted in CMS seeking public comments last year on whether TKA should be removed from the IPO list. While no official action was taken—as this was simply a solicitation for com- ments and not a formal proposal— CMS acknowledged that the majority of the comments were supportive of this move. At that time, CMS indicated
22 ASC FOCUS OCTOBER 2017 |
www.ascfocus.org
it would take these comments into con- sideration during future rulemaking. In its 2018 proposed rule, CMS proposed the removal of TKA from the IPO list, citing support from the pre- vious year’s comments in addition to acknowledging that it has “taken into account the recommendation from the summer 2016 Advisory Panel on Hos- pital Outpatient Payment (HOP Panel) meeting to remove the TKA proce- dure from the IPO list.” That proposal and presentation was coordinated by ASCA staff and members. The deci- sion to propose removal of TKA from the inpatient-only list also was based on CMS staff’s belief that the code can meet the following criteria:
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