Published 8/25/2017

AAOS comments on Quality Payment Program proposed rule

Washington, D.C. (August25, 2019) — On August 21, 2017, the American Association of Orthopaedic Surgeons (AAOS) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule that would make changes in the second year of the Quality Payment Program, including participation requirements for 2018. The Quality Payment Program—which replaces the flawed Sustainable Growth Rate (SGR) formula as required by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015—includes two tracks: the Merit-based Incentive Payment System (MIPS) track and the Advanced Alternative Payment Models (APMs) track. AAOS has been working closely with CMS to address a number of concerns related to the Quality Payment Program, including the need for additional flexibility and simplification, as well as protection for small, solo, and rural practices.

“The AAOS commends the Administration’s efforts to provide new flexibilities, especially for small and rural providers, in the Quality Payment Program as well as via the changes announced to the value-based payment models on August 15, 2017,” stated AAOS President William J. Maloney, MD in the AAOS comment letter. “Overall, we appreciate CMS’s aim to reduce the administrative burden on clinicians and to introduce greater flexibility in reporting requirements and eligibility rules. However, as surgical specialists, we would like to offer additional suggestions to improve the current rules to better reflect the needs of our surgeons and their patients. The AAOS thanks CMS for its solicitation and consideration of these comments and concerns.”

Specifically, AAOS applauded the increase in the low-volume threshold, noting that this will give clinicians in solo and small practices more time to prepare and meet the participation requirements. However, AAOS emphasized that there must still be more pathways for specialists to participate in the Quality Payment Program through the Advanced APM track. AAOS also commented on new proposals for virtual groups and the need for provision of clinician/practice data. Finally, the comments stressed that AAOS looks forward to engaging with CMS, “especially on developing outcome based measures for musculoskeletal care as well as on redesigning Medicare value-based payment models such that they are voluntary, physician-led, have accurate price setting, and provide access to data for all participants.”
Read the entire AAOS comment letter online here.

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Kristen Coultas