Published 9/18/2023

AAOS Comments on Proposed Medicare Payment Policy Changes for 2024

Washington, D.C. (September 18, 2023)—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 in the Medicare program for Calendar Year (CY) 2024. In both letters, AAOS urged the agency to reform the current physician reimbursement system to ensure high quality specialty care and equitable access to such care for Medicare beneficiaries.

Medicare Physician Fee Schedule
The AAOS’ concerns center around ongoing cuts to physician reimbursement, as the CY 2024 Medicare Physician Fee Schedule (MPFS) proposed rule includes a $32.75 conversion factor, which is a $1.14 (almost 3.26%) decrease from the $33.89 conversion factor for 2023. 

“AAOS is committed to helping create an equitable healthcare system for patients and physicians,” said AAOS President Kevin J. Bozic, MD, MBA, FAAOS. “Therefore, we urge CMS to support a statutory fix that provides an annual inflationary update for physicians, akin to all other providers covered by the Medicare payment system. Orthopaedic surgeons have been at the forefront of the transition to value-based care, and we are eager to work together to improve upon existing value-based payment and delivery models in the Medicare program. However, our ability to deliver high quality musculoskeletal care is hampered by inflationary pressures on practice expense. By some estimates, the MPFS conversion factor would have been double the amount being currently proposed, had it kept up with inflation.”

AAOS strongly disapproved of allowing sacroiliac joint arthrodesis codes (CPT codes 27279 and 2X000) to be covered in the office setting. Additionally, the AAOS opposes the implementation of Healthcare Common Procedure Coding System (HCPCS) code G2211 to be used with existing evaluation and management (E/M) visits, providing an add-on payment for complex patients and believes implementation of this code will negatively impact our surgeons and their patients. 

“This code is unnecessary due to the new office or outpatient E/M coding structure,” explained Dr. Bozic. “Existing codes are available for reporting the work and time across various complexity levels which make code G2211 duplicative of work that is already represented in the CPT code set.”

AAOS also commented on additional noteworthy proposals of the rule; supporting the expansion of telehealth services, further delay in implementation of the 2017-based Medicare Economic Index that was finalized in CY 2023, and an indefinite pause in implementation of the Appropriate Use Criteria program for advanced diagnostic imaging services.

Medicare Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems
AAOS supported the decision to extend the hospital market basket-based updates for ambulatory surgery centers (ASC). Additionally, AAOS requested that CMS permanently update ASC payments based on this methodology.

While CMS is not proposing to remove any services from the IPO List for CY 2024, AAOS urges CMS to consider appropriate expert knowledge and peer-reviewed evidence to make this decision in the future. Dr. Bozic reiterated that surgeons and their patients should decide on the appropriate setting for surgery and there should not be any mandates or pre-authorization requirements necessary to determine inpatient vs. outpatient surgery, even if a procedure moves out of the IPO list.

CMS is also proposing to adopt the Risk-Standardized Patient-Reported Outcome-Based Performance Measure (PRO-PM) for elective total hip and knee arthroplasties in the hospital outpatient setting. AAOS is encouraged by the move towards focusing on outcomes that matter to patients, and given our vast experience with PRO measurement, AAOS provided several recommendations for successful implementation, including allowing a slower ramp to mandatory reporting, clarifying the purpose of patient reported outcomes reporting and creating a reimbursement pathway for wider and easier adoption of outcomes measurement in the Medicare program.   

Read AAOS’ comments on CY 2023 PFS here.

Read AAOS’ comments on CY 2024 OPPS/ASC here.

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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 

Deanna Killackey 


Lauren Riley