September 27, 2019
The Alliance submitted comments to CMS addressing relevant wound care provisions in its CY2020 Hospital Outpatient Prospective Payment System. Comments flagged concerns and provided recommendations on a range of topics including:
  • The broad sweep to move all therapeutic services from direct to general supervision
  • The implementation of prior authorization for procedures that are often utilized to treat chronic wounds that threaten both life and limb
  • Payment methodologies for CTPs
  • Lump-sum episode based payment for a wound care episode
  • The single Ambulatory Payment Classification (APC) proposal and C-APC methodologies 
  • Inaccurate APC Group assignments for CTPs due to facilities' incorrect coding/billing, which for years has resulted in APC Group assignments that fail to reflect the true costs of the CTPs.



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Email: marcia@woundcarestakeholders.org
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