Submitted Comments

Items Related to Physician Fee Schedules

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

October 2, 2020

Comments to Proposed CY2021 Physician Fee Schedule

The Alliance submitted comments and recommendations to CMS’s proposed CY2021 Physician Fee Schedule. Our comments:

  • Oppose cuts in  payment for surgical procedures and physical therapy services and urged the Agency to prevent drastic cuts from occurring while physicians are still trying to recover and gain their financial footing from the effects of the pandemic.
  • Urge CMS to not only accept the RUC recommendations for the values of E/M codes, as they have proposed, but to also apply these updated values to the global procedure codes. We flagged that implementing new values for E/M codes when billed independently - but not implementing those same values in the global packages - disrupts the relativity in the entire physician fee schedule and creates specialty differentials even when performing the same work.
  • Recommend that the Agency consider creating a MIPS Value Pathway (MVPs) for Chronic Wound Management and utilize the QCDR measures which already exist for wound care. 
  • Encourage CMS to maintain a patient’s home as an originating site even when the Public Health Emergency expires. 

Read Alliance comments


September 10, 2018

Comments to CMS CY 2019 Physician Fee Schedule

The Alliance submitted comments to CMS' proposed CY 2019 Physician Fee Schedule supporting specific provisions to ease paperwork/documentation burdens, including:
  • Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit; 
  • Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient; 
  • Allowing physicians to choose between current documentation guidelines, documenting by time only, or documenting by medical decision making only; 
  • Removing the need to justify providing a home visit instead of an office visit. 
However,  the Alliance also used its comments to voice its strong opposition to the consolidation of Evaluation and Management codes and the corresponding reduction in payment for E/M services for those that provide the most complex care. The Alliance submitted a series of examples of unintended consequences that the proposal would create and urged CMS not to move forward with that provision. 
Read Alliance Comment
September 11, 2017

Comment on the proposed CY 2018 Physician Fee Schedule

The Alliance submitted comments to CMS on the proposed CY2017 Physician Fee Schedule. Comment focused on:
  • The under estimation and erroneous valuation of 2 CPT codes: CPT 29580 (Strapping of Unna Boot), and CPT 29581 (Application of multi-layer compression system).
  • Supporting the decision to update the equipment items and the amount of oxygen for hyperbaric oxygen therapy (HBOT) so that the amount of oxygen conforms to the RUC recommended value.
  • Requesting national payment rate for CPT Codes 97607 and 97608 - describing negative pressure wound therapy (NPWT) services using a disposable device - similar to the rate proposed in the CY2018 hospital outpatient proposed rule.
  • In response to CMS’s request for information on flexibility and efficiency opportunities to increase care, reduce costs and reduce burdens for clinicians and patients, the Alliance asked the agency to consider reform of the process it uses to assign new Healthcare Common Procedure Coding System (HCPCS) Level II billing codes to durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS). 
View Alliance Comment
December 19, 2016

Comments on MACRA final rule guiding MIPS and APMs

The Alliance submitted comments to CMS on its rule: Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Comments focused on ensuring that CMS considered of the impacts of the evolving value-based care/payment reform policies to wound care. The Alliance submitted comments to MACRA's quality physician payment proposed rule as well as on the "quality measures development plan," "patient relationships categories and codes," and "episode groups" draft policies.
View Alliance Comment 
September 6, 2016

Comments on the CY2017 Physician Fee Schedule

The Alliance submitted comments to CMS on its proposed Physician Fee Schedule update: "CMS-1654-P: Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Medicare Advantage Pricing Data Release; Medicare Advantage and Part D Medical Low Ratio Data Release; Medicare Advantage Provider Network Requirements; Expansion of Medicare Diabetes Prevention Program Model." Alliance comments focused on wound care services it viewed as improperly/inaccurately valued by the fee schedule. The Alliance also called for increased transparency on how CMS will use global service data. Additional, the Alliance requested that CMS review its criteria for the expansions of the upcoming Diabetes Prevention Program model as the Medicare Diabetes Prevention Program (MDPP).
View Alliance Comment 
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