Submitted Comments

Items Related to CTPs/(skin substitutes)

September 23, 2021

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.
See Alliance News Release
August 23, 2021

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.

See Alliance news release
August 6, 2021

Comments to Advisory Panel on Hospital Outpatient Payment

In advance of the Advisory Panel on Hospital Outpatient Payment public meetingon Aug. 23, 2021, the Alliance submitted written comments on specific provisions addressing payment for Cellular and/or Tissue Based Products for Skin Wounds (CTPs) and provided recommendations regarding CPT add-on codes and assignment of Ambulatory Payment Classifications (APCs) for the same size wound.

Read Alliance lettter
October 16, 2020

Alliance Opposes Payment Cuts for Physician & Physical Therapy Services in CMS’ Proposed CY2021 Physician Fee Schedule

October 2020 – In comments submitted to the Center for Medicare and Medicaid Services (CMS), the Alliance of Wound Care Stakeholders voiced its opposition to payment cuts from five to nine percent for surgical procedures and nine percent for physical therapy services as CMS proposes in its CY2021 Physician Fee Schedule. The Alliance also called on CMS to (1) Adopt all of the American Medical Association’s RUC recommendations including updated E/M values in procedure codes with 10- and 90-day global periods; (2) Maintain a patient’s home as an originating site even when the public health emergency expires; (3) Include additional telehealth codes for physical therapy services, and more.

Additionally, in comments submitted to CMS' CY2021 Hospital Outpatient Prospective Payment System proposed updates, the Alliance flagged concerns with provisions dealing with coding and payment for Cellular and/or Tissue based Products for skin wounds (CTPs, also known as skin substitutes). The Alliance supported inclusion of synthetic CTPs in the definition of “skin substitutes” but expressed significant concerns with the Agency’s proposed establishment of a unique C code to define an entire class of non-branded products and the placement of these products in the OPPS high cost payment package.
See Alliance News Update Summarizing Comments

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