Comments

Items Related to Prospective Payment System

September 24, 2018

Comments to CMS CY 2019 Hospital Outpatient Prospective Payment System (OPPS)

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
September 9, 2018

Comments to CMS DME/ESRD Prospective Payment System (PPS)

The Coalition submitted comments to CMS's End-Stage Renal Disease Prospective Payment System, which also covers the DMEPOS competitive bidding program. Comments focused on concerns surrounding the proposed calculation of single payment amounts (SPAs) and the gap-filling pricing methodology that applies when new technologies receive a new HCPCS code and CMS must establish a fee schedule amount for these new items.

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September 11, 2017

Comments to CMS on the proposed CY 2018 Hospital Outpatient Prospective Payment System

The Coalition submitted comments to CMS on “CMS 1678-P, the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs.” Coalition comments addressed:
  • Issues with the methodology for packaging of skin substitutes (Cellular and/or Tissue Based Product for Skin Wounds, or CTPs)
  • Support for grandfathering in eight CTP products to the high-cost bucket of the newly established threshold between low and high costs
  • Request for CMS to work with stakeholders to obtain the proper data for creating appropriate APCs for the application of CTP products.
  • 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).
View Coalition Comment
December 25, 2016

Comments to CMS on Interim Final Rule with Comment Period on Hospital Outpatient Prospective Payment Systems (OPPS)

The Coalition submitted comments to CMS on the Interim Final Rule for the Hospital Outpatient Prospective Payment Systems, CMS-1656-IFC. The Coalition states that under this payment model, hospitals would lose the ability to provide cellular/ tissue based products (CTPs) and Negative Pressure Wound Therapy (NPWT) products to patients. The Coalition recommends that CMS reconsider their choice to adopt the Medicare Physicians Fee Schedule (MPFS) so that hospitals may have the ability to provide NPWT and CTP products. 
view coalition comment
September 6, 2016

Comments to CMS on Hospital Outpatient Prospective Payment System (PPS)

The Coalition submitted comments to CMS on the CMS on Hospital Outpatient Prospective Payment System (OPPS) proposed rule, CMS-1656-P, on issues regarding the packing of CTPs. The Coalition states that CMS has been using flawed data to calculate the setting rate for CTPs, something the Coalition has informed CMS about for years. The Coalition states that CMS needs to require correct coding for CTPs, ensuring that claims forms reflect the correct number of units being billed for. Furthermore, the Coalition recommends that whether or not a product falls into the low cost bucket or high cost bucket should be a function solely of the size of the CTP, regardless of its anatomic location.
view coalition comment
August 26, 2016

Comments to CMS on CY 2017 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements

The Coalition submitted comments to CMS on the CY 2017 Home Health Prospective Payment System (PPS) Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements. The Coalition noted that its members had been involved and closely monitoring the creation of the Patient Access to Disposable Medical Technology Act of 2016. That Act became section 504 of the Consolidated Appropriations Act of 2016. Because Coalition members were so closely monitoring that process, the Coalition was very aware of the original congressional intent of these statutes as they relate to add-on payments to home health agencies (HHAs) and Negative Pressure Wound Therapy (NPWT). The Coalition clarified in comments that the intent of these statues was not for home health agencies to absorb to entire cost of care for a patient requiring NPWT in the home. The Coalition recommended that CMS revise their proposal to match the Congressional intent and language revolving around disposable NPWT devices in home health settings. 
view coalition comment
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