Remove Patient Access Barriers by Correcting Inadequacies in CTP Payments in the 2023 Hospital Outpatient Prospective Payment System Proposed Rule, Alliance of Wound Care Stakeholders Urges CMS

Sept. 19, 2022 – The Alliance of Wound Care Stakeholders urged the Centers for Medicare and Medicaid Services to update inadequate payment methodologies for cellular and/or tissue-based products for skin wounds (CTPs, or “skin substitutes”) to ensure appropriate access to care in the hospital outpatient/provider-based department (PBD) site of service. In comments submitted to CMS’s proposed 2023 Hospital Outpatient Prospective Payment System updates, the Alliance forwarded specific recommendations to correct policy and payment challenges that are negatively impacting access to CTPs in provider-based departments. These include...
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Comments to Proposed 2023 Hospital Outpatient Prospective Payment System (HOPPS)

The Alliance submitted comments to CMS' proposed CY 2023 Hospital Outpatient Prospective Payment System expressing significant concerns with several provisions within the "skin substitute" section of the proposed rule. In its detailed feedback to CMS, the Alliance:  

• Opposed CMS' renaming the term "skin substitutes" to "wound care management products."
• Opposed CMS' proposal to change CTP's HCPCS codes from “Q” codes to “A” codes (supply codes). Called out some of the concerning cross-over issues from the proposed 2023 Physician Fee Scheduleand recommended that the Agency publish ASPs and continue to accept ASP pricing for inclusion in payment methodology for all CTPs in order to achieve savings and consistency.
• Urged CMS to remove patient access barriers by correcting inadequacies in CTP payments. The Alliance once again submitted the recommendation that CMS make policy updates to (1) Enable Provider-Based Departments to be reimbursed for an adequate amount of CTP products for larger wounds and (2) Equalize payment for the application of CTPs wounds of the same size, no matter where they are on the body.

Alliance Alerts CMS to the Harmful Impacts of Wound Care Service Payment Reductions Proposed in the CY2022 Physician Fee Schedule and Hospital Outpatient Payment Rules

September 2021 – The Alliance of Wound Care Stakeholders voiced opposition to payment cuts that would negatively impact wound care providers and their patients in recent comments to the Center for Medicare and Medicaid Services’ (CMS) proposed CY2022 Physician Fee Schedule and proposed Hospital Outpatient Prospective Payment System (HOPPS) regulations. The Alliance challenged cuts to surgical procedures, physical therapy services, disposable negative pressure wound therapy and compression payment as well as provided recommendations to remove barriers to CTPs. The final regulations from CMS are expected to issue in November.
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CMS’ Advisory Panel on Hospital Outpatient Payment Unanimously Approves Alliance of Wound Care Stakeholders’ Recommendations that Would Correct Inadequacies in CTP Payments, Remove Barriers to Access

August 26, 2021 – At its public meeting on August 23, the Advisory Panel on Hospital Outpatient Payment unanimously approved two recommendations made by the Alliance of Wound Care Stakeholders that, if accepted and implemented by CMS, would positively impact wound care by correcting flaws in the payment that have negatively impacted reimbursement for cellular and tissue-based products for wounds (CTPs, also known as skin substitutes) and removing barriers to access for these important wound care products. While the Advisory Panel submits recommendations to CMS for consideration, the Agency is not obligated to move its recommendations forward. That is why now is the time for the wound care community to make its voice heard to CMS so that these recommendations are included in the OPPS policy as it is revised and finalized. Here's how.

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