Published 9/12/2022

AAOS Comments on Proposed Medicare Payment Policy Changes for 2023

Washington, D.C. (September 12, 2022)—The American Association of Orthopaedic Surgeons (AAOS) issued formal comments to the Centers for Medicare & Medicaid Services (CMS) on the agency’s proposed payment policy changes for Calendar Year (CY) 2023. In both letters, AAOS urged the agency to address growing health care costs, expand access to care and ease physician burden as they continue to navigate patient care, amidst financial and practice management challenges exacerbated by the pandemic.

Medicare Physician Fee Schedule
The AAOS’ concerns center around ongoing cuts to physician reimbursement, including a nearly 4.5 percent conversion factor reduction, while practice expenses continue to rise. In the letter, AAOS President Felix H. “Buddy” Savoie III, MD, FAAOS, explained: “With inflation soaring to 40-year highs this year, ongoing and scheduled statutory payment cuts and many physician practices still dealing with pandemic-related financial and staffing issues, the current proposal from CMS undermines the long-term sustainability of physician practices while threatening patient access to physicians participating in Medicare.”

The AAOS is urging CMS to reform the current physician reimbursement system and create value-based payment models that include incentives tailored to the distinct needs of specialty physicians. It is also  urging CMS to apply the RUC-recommended changes to the evaluation and management component of surgical global codes to maintain the relativity of the Physician Fee Schedule.

Dr. Savoie wrote, “The statutory prohibition on paying physicians differently for the same work applies regardless of code valuation method and the incremental increases should apply to all physicians.”

Medicare Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems
The AAOS’ comments address the “dangerous precedent” of increasing prior authorization in the hospital outpatient setting and its negative impact on patient care. Dr. Savoie stated that requiring approval from a third-party which is removed from clinical decision-making “erodes the doctor-patient relationship, and the ability to make decisions that are in the best interest of the patient.” He added that it undermines the years of training and schooling physicians go through, and he requests that the proposal be formally removed from the final CY 2023 OPPS rule.

Another element of the rule that AAOS addressed is the proposal to remove CPT code 22632 (Arthrodesis) from the Inpatient Only (IPO) list. While AAOS believes there is enough evidence to prove the primary procedure can be done safely in the outpatient setting, it reiterated that “surgeons should decide on the actual setting of surgery and there should not be any mandates and pre-authorizations necessary to determine inpatient vs. outpatient surgery even if a procedure moves out of the IPO list.”

Read AAOS’ comments on CY 2022 PFS here.

Read AAOS’ full comments on CY 2023 OPPS/ASC here.

# # #

About the AAOS
The American Association of Orthopaedic Surgeons (AAOS) Office of Government Relations promotes and advocates the viewpoint of the orthopaedic community before federal and state legislative, regulatory, and executive agencies. Based in Washington, DC, with additional staff in the Academy’s headquarters in Rosemont, Illinois, the Office of Government Relations identifies, analyzes, and directs all health policy activities and initiatives to position the AAOS as the trusted leaders in advancing musculoskeletal health.

For more information on all AAOS advocacy efforts, visit

Contact AAOS Media Relations 

Kristen Coultas