The work relative value units (“RVUs”) assigned for HCPCS code G0465 do not accurately reflect the time, intensity, mental effort and judgment, technical skill and physical effort associated with the delivery of autologous platelet rich plasma (“PRP”) or other blood-derived products for the treatment of chronic, non-healing diabetic wounds, the Alliance told CMS in a letter requesting that the code be considered - and the work RVUs updated - under the "Potentially Misvalued Code" process. The Alliance also asked CMS to clarify its billing and reimbursement policies for multiple applications of an autologous blood-derived product when used to treat a large surface area wound and/or to treat multiple wounds on the same date of service. "Multiple product kits may be needed... [and] requiring that an additional application of autologous blood-derived product be subject to a 50 percent reduction in reimbursement for the code means that the cost of the product is not covered. Accordingly, clinicians are not able to furnish multiple applications of autologous blood-derived product on the same date of service in the physician office setting, even when it is medically necessary and appropriate to do so." The end result: "Patients with multiple wounds or wounds with large surface areas either need to be treated on separate days or in the hospital outpatient setting, which creates a disparity in access and leads to increased Medicare costs for patients who could have otherwise been treated safely and effectively in the physician office setting on the same day," the Alliance wrote.

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