Seven Devices Medicare Priced Off a Knee Replacement

On July 2, CMS quietly posted a spreadsheet to the CY 2027 outpatient proposed rule and did not put it in the downloads list. It sits under Related Links, named 2027 NPRM OPPS Section 4135, and it is the only place the agency published the numbers that decide what a hospital or an ASC gets paid for every non-opioid pain product Medicare separately pays for.

Table 71 of the rule, the one that lists those products, is a TIFF image in the Federal Register text. So is the CY 2026 version. The spreadsheet is the machine-readable copy, and almost nobody has opened it.

We did. Twenty products, seven drugs and thirteen devices, each with a per-date-of-service dollar cap. Seven of the twenty carry the exact same number: $2,228.56.

Not similar. Identical, to the cent (chart below).

One Number, Seven Devices

The statute is section 4135 of the Consolidated Appropriations Act, 2023, and it does two things. It forbids CMS from packaging a qualifying non-opioid pain product into the procedure payment, and it caps the separate payment at 18% of the fee schedule amount for the service the product is used with.

CMS operationalized that 18% as the volume-weighted average of the payment rates for the top five procedures the product would otherwise have been packaged into. Sensible enough when you have claims.

For eight of the twenty products, CMS has no claims at all.

The footnote in the file says what happens then, typo included: "In the absence of claims data, we assumed equal untilization of the qualifying product among the provided primary procedures." And the provided primary procedures, for seven of the eight, are the same five every time:

• 27447, total knee arthroplasty, at $14,628.91
• 27130, total hip arthroplasty, at $14,628.91
• 23472, total shoulder arthroplasty, at $20,224.44
• 29827, shoulder arthroscopy with rotator cuff repair, at $8,566.15
• 29881, knee arthroscopy with meniscectomy, at $3,855.98

One unit each. Sum $61,904.39, mean $12,380.88, times 18%, and you land on $2,228.558. Round it and you have the number sitting on seven rows of that spreadsheet.

So an electronic ambulatory infusion pump, a set of echogenic nerve block needles, a perforated infusion catheter, a conduction catheter set, a CADD-Solis pump, a reusable ambIT pump and a cryo-pneumatic cold wrap all get the same cap, because none of them is being priced off itself. They are being priced off a default basket of five orthopedic procedures.