Over the past four years, CMS has placed the issue of reforming the CTP payment methodology in the Hospital Outpatient Prospective Payment System (OPPS) proposed/final rules, soliciting feedback on Episodic Payment, Single APC, and Comprehensive APC. In March, the Alliance developed and proactively submitted to CMS its recommendations regarding CTP payment methodology for the Agency to  consider as it begins development of proposed rules for CY 2022. In summary, the Alliance encouraged CMS to propose a CTP/skin substitute payment methodology for CY 2022 implementation that collapses the “high cost” and “low cost” products, allows separate payment for the add-on codes, and tracks the base codes and add-on codes to unique APC Groups which are updated annually. See detailed recommendation in CMS letter, below.

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