The Alliance provided written and oral comments to CMS' August 2020 CMS Advisory Panel on Hospital Outpatient Payment. Comments focused on provisions related to "synthetic skin substitutes" and included recommendations to:

• Eliminate the new code C1849 – synthetic skin substitutes resorbable and require any synthetic skin substitute to apply for an appropriate HCPCS Q code to be considered a “skin substitute.”
• Remove placement of the C1849 synthetic skin substitute products from the high cost tier.
• Change the current “skin substitute” terminology to “cellular and or tissue based products for skin wounds."

See full comments, below.

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