Comments to CMS on the proposed CY 2018 Physician Fee Schedule

The Coalition submitted comments to CMS on “CMS 1676-P: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2018.” The Coalition comments requested that CMS consider establishing office-based PE RUV’s for disposable Negative Pressure Wound Therapy (dNPWT). Comments also noted issues with codes and payment rates for NPWT services. The Coalition recommended that CMS assign direct cost inputs to disposable negative pressure wound therapy, which would allow the establishment of national payment rates for CPT codes 97607 and 97608 in the final Physician Fee Schedule (PFS) rule for CY 2018. 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 Coalition 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).
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