The Alliance submitted detailed comments to CMS' proposed 2024 Medicare Physician Fee Schedule focused on a range of issues including:

• Payment methodologies for CTPs (skin substitutes): the Alliance provided recommendations and workable alternative solutions to CMS’s proposed bundling of CPTs, encouraging the agency to utilize and enforce the submission of ASP for all CTPs and publish all CTPs’ ASPs in the data file.
• Valuation of hyperbaric oxygen under pressure (HCPCS code G0277): the Alliance urges CMS to adopt the RUC recommendations for direct PE inputs for G0277 that the clinical labor intra-service time should be 30 minutes, consistent with the code descriptor, and not 15 minutes as proposed.
• Clinical Labor Updates: the Alliance again voiced its opposition to the Clinical Labor Update and its significant cuts in reimbursement that undermine the long-term financial viability of physician practices and patient seniors’ access to critical treatments and procedures.

See the Alliance's full comments below. 

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