January 3, 2023
The Alliance submitted comments to the final 2023 Medicare Hospital Outpatient PPS rule, questioning why CMS again failed to adopt the recommendations of its Hospital Outpatient Payment Panel related to skin substitutes (CTPs) and emphasizing flaws in the Agency's rationales. In 2021 and 2022, the HOPPs panel endorsed the Alliance’s policy update recommendations to enable provider-based departments to (1) be reimbursed for an adequate amount of CTP products for larger wounds so that they do not need to absorb the cost themselves or refer patients out, and (2) to equalize the payment for CTP application for wounds/ulcers of the same size no matter the anatomic location. Yet these have not been included in the HOPPS rule. "Over the nine plus years that CMS has proposed and implemented packaging for skin substitutes, the Alliance has submitted substantive data to CMS showing that the data used and the conclusions that CMS has made as it relates to the rate setting for CTPs is flawed...CMS erroneously believes that facilities are making significant profit on skin substitutes which is perpetuating the flawed logic. As a result of this flawed logic, CMS is making decisions not in the best interest in Medicare beneficiaries who are patients with wounds/ulcers," the Alliance wrote, urging the Agency to adopt the Panel recommendations related to skin substitututes in the next round of rulemaking. See full comments below.

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