WOS recently joined the AAOS by signing onto two comment letters.
Please find key takeaways below.
AAOS CY 2026 OPPS/ASC Comments: AAOS supports CMS’s proposed 2.4% ASC payment update, the continued use of the hospital market basket methodology, and exclusion of the 2% 340B offset from ASC rate-setting. We endorse broader use of complexity adjustments and the creation of a new Level 7 MSK APC to ensure accurate valuation of advanced orthopaedic procedures. At the same time, AAOS strongly opposes eliminating the Inpatient-Only List for all musculoskeletal procedures without sufficient peer-reviewed evidence, and urges CMS to preserve physician discretion and clarify Two-Midnight exceptions for Medicare Advantage. We support clinically driven expansion of the ASC Covered Procedures List with safeguards for patient safety, transparent nominations, and aligned APC policies, as well as broader and more timely coverage of innovative devices. AAOS also supports unbundling non-opioid pain therapies from APCs but cautions against CMS’s overly narrow interpretation of the NOPAIN Act. Finally, AAOS encourages alignment of quality reporting programs, expanded use of QCDRs, and thoughtful site-neutral payment reforms paired with physician fee schedule improvements and protections for rural access. View Full Letter
AAOS CY 2026 MPFS Comments: AAOS welcomes the proposed positive update to the CY 2026 conversion factor, the first in six years, but emphasizes that it remains historically low and insufficient to offset decades of mounting financial pressures on physician practices. We urge CMS to avoid implementing the proposed 50% cut to indirect practice expense RVUs for facility-based services, to revisit the budget neutrality assumptions for G2211, and to withdraw the flawed –2.5% “efficiency adjustment,” particularly for codes recently created or revalued. AAOS also cannot support the Ambulatory Specialty Model as currently designed for low back pain, citing serious concerns with attribution, scoring, and limited applicability, and instead calls for CMS to collaborate on a more effective model. Finally, AAOS supports CMS’s proposal to clarify QCDR readiness for MVP participation beginning with the 2026 performance period. View the Full Letter
