The Alliance submitted detailed comments to CMS on a range of provisions in the proposed Physician Fee Schedule that impact wound care providers. Comments focused on:

• Evaluation and Management Codes
• The conclusions of three RAND Corporation reports utilized in the report to support certain provisions (CMS had contracted RAND to collect data on the number and level of post-operative visits for surgical global codes provided to Medicare beneficiaries)
• Relative Value Units (RVUs) for Physical Therapy
• Practice Expense (PE) RVUs for Disposable Negative Pressure Wound Therapy (CPT Codes 97607 & 97608)
• Open Wound Debridement (CPT Codes 97597 and 97598)
• Ultrasonic Wound Assessment (CPT Code 97610)

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

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