Regulatory Advocacy

The AAO-HNS has a long history of working closely with regulatory agencies (e.g., Centers for Medicare & Medicaid Services, U.S. Food and Drug Administration) to maintain our visibility and credibility with national representatives regarding federal regulatory issues.

We believe that advocacy is the key to defining the future of otolaryngology. Federal regulatory advocacy is a top priority of the AAO-HNS.

CMS Releases Final FY2017 Medicare Fee Schedule
On November 2, the Centers for Medicare & Medicaid Services (CMS) released the 2017 Medicare Physician Fee Schedule final rule, which included key provisions relating to the collection and analysis of data for global surgical services. 

In response to intense advocacy from the AAO-HNS and others in the Surgical Coalition, the final rule drastically reduces the expected reporting burden for surgeons by limiting the number of codes that require reporting, delaying the start date, designating only certain states for reporting, and excluding small practices.

The key changes in the final rule version of the global surgical services data collection and analysis provisions are: 

  • The reporting period begins July 1, 2017 instead of January 1, 2017. 
  • The reporting requirements are restricted to practitioners in practices with 10 or more practitioners in Florida, Kentucky, Louisiana, Nevada, New Jersey, North Dakota, Ohio, Oregon, and Rhode Island rather than requiring all Medicare practitioners to report.
  • Instead of a modifier, practitioners are required to report on claims data on post-operative visits furnished during the global period for the specified procedures using CPT code 99024.
  • The specified procedures are procedures that are: a) furnished by over 100 practitioners and b) are either furnished more than 10,000 times annually or have annual charges that are greater than $10 million.

After a multifaceted regulatory and legislative advocacy campaign, the changes represent a substantial "win" for the surgical community. Learn more

In addition to provisions regarding data for global surgical services, the rule includes finalized proposals for practice expense adjustments and Appropriate Use Criteria for Advanced Diagnostic Imaging requirements. The Academy is evaluating the final rule and will submit comments to CMS.

CMS Releases Final 2017 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment Rate
On November 1, CMS released the 2017 Hospital Outpatient Prospective Payment System (HOPPS) and Ambulatory Surgical Center (ASC) Payment Rate. The Academy is currently evaluating the final rule and will submit comments to CMS.

CMS Releases Post-SGR Payment Policy with MIPS and APM Final Rule
On October 14, CMS released the final rule, solidifying the details of the two new payment update tracks, the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). In the final rule, CMS adjusted several key aspects of the program the Academy submitted comments last spring. To learn more click here.