The Alliance submitted comments to CMS' proposed CY 2022 Hospital Outpatient Prospective Payment System expressing significant concerns with several provisions within the "skin substitute" section of the proposed rule. Comments specifically flagged issues and provided detailed recommendations surrounding:

• the definition and coding of synthetic resorbable skin substitutes,
• payment issues in provider based departments impacting Medicare beneficiaries access to skin substitutes (“cellular and/or tissue based products for skin wounds” or CTPs), and
• alternative payment methodology proposals for skin substitutes in the CY 2023 proposed rule.

The Alliance also encouraged CMS to adopt the Agency's Advisory Panel on Hospital Outpatient Payment recommendations to:

• assign the existing CPT add-on codes (15272 and 15276; 15274 and 15278) to an appropriate APC group allowing for payment and issue an exception for the payment of CTP application add-on codes, and
• assign the application of skin substitute codes for wounds/ulcers on the feet to the same APC group as the application of skin substitutes for wounds/ulcers on the legs.

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