September 11, 2023
The Coalition submitted comments to CMS' proposed 2024 Medicare Physician Fee Schedule voicing opposition to the Agency's proposal to treat CTPs (skin substitutes) as “incident to supplies” when furnished in non-facility settings and to include the costs of these products as resource inputs in establishing practice expense RVUs for associated physician’s services, rather than reimburse them separately. The Coalition outlined specific concerns, requested that CMS withdraw the proposal, and recommended instead that CMS maintain and enforce ASP pricing – "the most consistent pricing for CTPs that should and can be utilized across payment settings."
Read Coalition Comments
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