March 15, 2022
On March 15, the Alliance met with three divisions of CMS – Hospital and Ambulatory Policy Groups (Division of Practitioner Services and Division of Outpatient Care), Technology Coding and Pricing Group (Division of Coding and DRG) – to discuss how the inconsistent HCPCS code assignments for CTPs ("skin substitutes") have led to problematic issues in both the physician office setting and in hospital outpatient provider-based departments. The Alliance alerted CMS to the unintended consequences in the physician’s office and the hospital outpatient provider based departments when CMS began assigning “A” and “C” codes instead of the traditional Q codes to skin substitutes, and presented six specific recommendations for CMS consideration to bring consistency to coding for CTPs and synthetic CTPs and correct the unintended impacts being experienced under current coding policies. 

To illustrate how the impact of decisions made in one division impacts the others, the Alliance also provided to CMS a detailed chart showing the chronology of skin substitute policies, providing context and timelines as to how HCPCS coding decisions have impacted the physician fee schedule and hospital outpatient policies. See Alliance presentation, recommendations and CTP policy chart below.

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