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

• Cellular and/or Tissue based Products for Skin Wounds (CTPs): The Alliance supported CMS’ proposal to pay for CTPs separately, without bundling or packaging, as the unbundling will now enable hospital outpatient departments to be reimbursed for CTP product for larger wounds as well as received equalized payment for the application of CTPs on wounds/ulcers regardless of anatomic location. Comments addressed these issues as well as CMS' related proposals on “incident to supplies” payment methodology and creation of new reimbursement categories for CTPs based on FDA regulatory categories.
• Blood and Blood Derived Products: The Alliance supported continued payment of Blood and Blood Derived Products separately rather than being packaged. 
• Point of Care Imaging (POCI): Alliance responded to CMS’ request for feedback on its Software as a Service (SaaS) approach, recommending that POCI solutions for wound care be considered in future SaaS reimbursement frameworks. CMS should develop specific billing codes (e.g., for image capture, interpretation, and care planning) for approved wound care imaging tools, the Alliance recommended.
• Therapeutic Shoes for Patients with Diabetes: Highlighting easily correctable barriers that delay care, the Alliance recommended that CMS update burdensome requirements in Medicare’s Therapeutic Shoe Program for Patients with Diabetes.
• Total Contact Casting (TCC): The Alliance asked CMS to fix current inconsistencies in National Correct Coding Initiative policies that make it difficult for hospital outpatient departments to get paid separately for TCC when provided on the same date of service as a debridement or CTP application.

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