Published 8/24/2023

AAOS Comments on Request for Information for Episode-Based Payment Model

Washington, D.C. (August 24, 2023)—Last week the American Association of Orthopaedic Surgeons (AAOS) submitted comments to the Center for Medicare and Medicaid Innovation (CMMI) in response to a request for information they released in July regarding the development of Episode-Based Payment Models (CMS-5540-NC).

In its letter, AAOS expressed their support for engaging physicians in the design and implementation of alternative payment models and urged the Centers for Medicare & Medicaid Services (CMS) to consider the impact that interoperability, multi-payer alignment of measures, and administrative burden have on the ability of physicians to successfully participate in alternative payment models.

As a thought leader in reducing the complexities of value-based care and as clinical experts delivering high-value, patient-centered musculoskeletal care, AAOS shared their insights and recommendations which include:

  • Expanding alternative payment model (APM) episodes beyond 30 days, and encouraging the agency to consider episodes longer than 90 days
  • Only considering voluntary models with participation incentives– as a mandatory model would be in the disinterest of collaborative, patient-centered care
  • Ensuring that barriers, such as interoperability, multi-payer alignment of measures, and administrative burden are resolved in future models
  • Finding an approach that allows downstream risk sharing with orthopaedic surgeons
  • Exploring a pilot program for the management of chronic and prevalent conditions by orthopaedic surgeons

In July, AAOS and several physician organizations, requested an extension to the proposal’s 30-day comment period. While the request was denied by CMMI, the agency agreed to meet with AAOS for further discussions.

“The AAOS is excited to partner with CMS and offer our expertise based on our extensive experience with the design, implementation, and evaluation of value-based payment models. As leaders in payment model transformation, the AAOS is well-positioned to ensure that changes to the way hospitals and physicians are paid for their services ultimately provides value to Medicare beneficiaries and their families, while reducing the administrative burden on the healthcare system,” wrote AAOS President Kevin J. Bozic, MD, MBA, FAAOS.

Read the full letter 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