The Alliance submitted comprehensive comments to CMS’ proposed CY 2026 Hospital Outpatient Prospective Payment System (CMS-1834-P) focused on a range of provisions impacting wound care, including:

• CTPs: The Alliance commended CMS efforts to improve program integrity in the reimbursement of CTPs. The Alliance has advocated over the years for CMS to fix flaws and inadequacies in the OPPS bundled payment methodology and applauds the Agency’s current efforts to do so. The Alliance supports CMS’ proposal to pay for CTPs separately, as unbundling will finally enable hospital outpatient departments to be reimbursed for CTP products for larger wounds as well as receive equalized payment for the application of CTPs regardless of a wound’s anatomic location – fixes that the Alliance has elevated to CMS for years. Comments addressed details of CMS’s proposed “incident to supplies” payment methodology and the creation of new reimbursement categories for CTPs based on FDA regulatory categories versus a single payment approach.
• Blood and Blood Derived Products payment
• Point of Care Imaging (POCI) reimbursement under  Software as a Service (SaaS) frameworks
• Total Contact Casting (TCC) coding and payment policy clarification/correction
• Therapeutic Shoes for Patients with Diabetes access barriers
• Price Transparency

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