September 24, 2018
The Coalition submitted comments to CMS in response to its proposed CY 2019 Hospital Outpatient Prospective Payment System (PPS) and Ambulatory Surgical Center Payment Systems.  Comments focused on provisions related to packaging and payment methodology for cellular and tissue-based products for wounds (CTPs), and pass through status for CTPs. The Coalition recommended that CMS:
  • move quickly in establishing the CTP payment reforms 
  • work with wound care stakeholders in creating whatever methodology is ultimately chosen 
  • be transparent in providing the data utilized 
  •  support reduced copays for Medicare beneficiaries. 
  • utilize the correct CTP cost information 
  • ensure that facilities are billing correctly for CTPs 
  • ensure that patients come first and they continue to have access to this valuable adjunctive therapy
  • conduct an impact analysis and provide its results in a transparent manner. 
  • take into consideration that there are a wide variety of patients with chronic wounds, that wounds heal differently and that treatment is individualized

Read Coalition comment
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Bethesda, Maryland 20814
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