September 5, 2023
Via submitted comments and testimony to CMS’ Advisory Panel on Hospital Outpatient Payment, the Alliance submitted five recommendations to correct inadequacies in payments for CTPs ("skin substitutes") and remove barriers to access. If accepted and implemented by CMS in upcoming Hospital Outpatient Prospective Payment System updates, these recommendations would positively impact wound care by correcting flaws in the payment that have negatively impacted reimbursement for CTPs and removing barriers to access for these important wound care products. The recommendations were overwhelmingly approved by the Panel and elevated in its  report to CMS:
  1. Assign the existing CPT® add-on codes (15272, 15276, 15274, 15278) and HCPCS codes (C5272, C5276, C5274, C5278) to appropriate APC groups allowing for separate payment and issue an exception to separately pay for these add-on codes.
  2. Assign the CPT and HCPCS codes for the same size wound, regardless of anatomical location on the body, to the same APC groups.
  3. Assign all new CTPs with both Q and A HCPCS codes, to the low-cost APC groups until a manufacturer provides cost information to CMS.
  4. Realign both the high-cost and low-cost application procedure codes to higher paying APC groups that reflect the current average sales prices of all CTPs. Consistently publish and use the ASP of all CTPs.
  5. Don’t assign CTPs that are not in sheet form (e.g., gel, powder, ointment, foam, liquid, or injected) to any APC group because these products are not allowed to use the current application codes of 15271-15278 or C5271-C5278, which drives the APC group assignment.

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