Comments to CY2020 Hospital Outpatient Prospective Payment System

The Coalition submitted comments to CMS regarding its proposed CY2020 Hospital Outpatient Prospective Payment System Updates. Comments focused primarily on the provisions related to payment methodologies for cellular and tissue-based products for skin wounds (CTPs) and offered the following recommendations for CMS to take into consideration in the development process:

1. CMS should move quickly in establishing the CTP payment reforms
2. CMS must work with wound care stakeholders in creating whatever methodology is ultimately chosen
3. CMS must be transparent in providing the data utilized.  
4. CMS’s revised payment methodology should support reduced copays for Medicare beneficiaries.
5. CMS needs to utilize the correct CTP cost information
6. CMS must ensure that facilities are billing correctly for CTPs
7. CMS must ensure that patients come first and they continue to have access to this valuable adjunctive therapy.
8. When CMS proposed packaging, the Agency did not perform an impact analysis on payment rates or patient access. Therefore, CMS must conduct an impact analysis and provide its results in a transparent manner.
9. CMS should take into consideration that there are a wide variety of patients with chronic wounds, that wounds heal differently and that treatment is individualized.

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