The Alliance submitted comments to the proposed CY 2022 Physician Fee Schedule supporting and encouraging implementation of provisions including: the delay of the Appropriate Use Criteria penalties, permitting Physician Assistants to bill for their services directly, and expansion of the Medicare Diabetes Prevention Program. Importantly, the Alliance also voiced concern with several specific provisions relevant to the wound care provider community, flagging the negative impacts of:

• proposed cuts to payment for surgical procedures and for physical therapy services
• proposed reduction to the payment of Disposable Negative Pressure Wound Therapy (dNPWT), CPT codes 97607 and 97608, by 22%, when performed in physician office settings
• proposed cuts to the CPT code fees for application of multilayer compression
• the creation of G codes for application of synthetic resorbable skin substitutes rather than use of Q codes
• the proposal that synthetic resorbable skin substitutes be treated as “incident-to” supplies in the physician office

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