The Alliance submitted comments to CMS’s proposed CY2021 Hospital Outpatient Prospective Payment System. Our comments:

• Encouraged use of the “Cellular and/or Tissue Based Products for Wounds “(CTPs)  terminology in policymaking, in place the currently used “skin substitutes.”
• Supported inclusion of Synthetic CTPs in the definition of “skin substitutes” but expressed significant concerns with the Agency’s proposed establishment of the code C1849 (“Skin substitute, synthetic, resorbable skin substitute per square centimeter) to define an entire class of non- branded products and its placement in the OPPS high cost payment package. The Alliance reviewed the impacts of this code as proposed and submitted a number of alternative recommendations.  
• Requested that Hyperbaric Oxygen Therapy be added to the list of services that require direct supervision
• Sought clarification on how provider based departments should make decisions on the level of service assigned to code G0463 (hospital outpatient clinic visit) once the new 2021 E/M guidelines are in place.

See additional recommendations submitted to CMS in the full-text comments, below.

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