January 18, 2023
The Alliance informed CMS that it does not support the packaging of skin substitutes in the physician office, as recent experience shows that packing has not worked well for patients or for hospital outpatient departments. In addition to significant flaws in the current payment methodology, there have been issues with patient access to care as well as limiting clinician’s choice of product. "We really need to have more information from the Agency on CMS’s intent, goals or criteria for packaging skin substitutes in the physician office," the Alliance said as part of oral testimony offered at CMS' Skin Substitutes Town Hall convened to collect stakeholder feedback related to changes in payment and terminology of skin substitute products being considered under the Physician Fee Schedule. The Alliance recommended that CMS develop and put forward a policy "Framework Document" for stakeholder input prior to initiating rulemaking. In the meantime, the Alliance urged CMS to continue its longstanding policy of recognizing and providing separate payment for CTPs products under the ASP methodology. Savings could be realized, the Alliance told CMS, if all skin substitute companies to submit ASP pricing to the Agency and all companies’ ASP data are published in the ASP data file.

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