In comments to CMS's draft 2023 Physician Fee Schedule, the Alliance alerted the Agency that the proposed changes to reclassify all CTPs as “supplies incident to a physician service” and package payment into practice expenses will create barriers to care that could ultimately lead to increased amputations and infection for patients with chronic non-healing wounds. The Alliance urged CMS to remove the proposed CTP provisions from the final 2023 Physician Fee Schedule that will issue later this year, or, at very least, delay implementation until patient access issues can be further studied and policy implications vetted with key stakeholders.

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