January 18, 2023
The Coalition provided oral comment at the Skin Substitutes Town Hall convened by CMS to collect stakeholder feedback related to changes in payment and terminology of skin substitute products under the Physician Fee Schedule. The Coalition provided perspective to the Agency on its four proposed questions, addressing: 1) What should we consider as part of CMS efforts to ensure consistent, fair, and appropriate payment for services and products across different settings of care? 2) How could we ensure that valuation under the PFS adequately accounts for variability in relative resource costs of different skin substitute products as supplies within the Practice Expense Relative Value Unit (PE RVU) methodology? 3) Are there similarly resourced groups of products/services that could inform how payment might be stratified without risking access to services? 4) What should we consider as alternatives regarding any potential changes to terminology?
The Coalition urged CMS to be more transparent and provide more information to stakeholders before any rulemaking on this issue takes place and recommended that the Agency issue a framework document prior to any rulemaking for stakeholders to respond to.

See Coalition Testimony
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