Comments

1. assign the existing CPT® add-on codes (15272, 15276, 15274, and 15278) and HCPCS codes (C5272, C5276, C5274, and C5278) to appropriate APC groups allowing for separate payment; and issue an exception to separately pay for these add-on codes.
2. assign the CPT and HCPCS codes for the same size wound, regardless of anatomical location on the body, to the same APC groups.
3. assign all new CTPs with both Q and A HCPCS codes to the low-cost APC groups until a manufacturer provides cost information to CMS.
4. realign both the high-cost and low-cost application procedure codes to higher paying APC groups that reflect the current average sales prices of all CTPs.
5. not assign CTPs that are not in sheet form (e.g., gel, powder, ointment, foam, liquid, or injected) to any APC group.

• The policies are not in the best interest of patients.
• The policies are not supported by clinical evidence or guidelines. Evidence has been omitted from the policy review. What has been utilized is either not the most currently available, or is used in such a way that is contradictory to the points Novitas/FCSO is trying to make.
• There is NO new evidence to support the movement of more than 40 products from the covered to the non-covered list.

• Include the Hospital Harm - Pressure Injury eCQM in the CY 2023 Inpatient PPS final rule, or alternatively, propose this eCQM in next year’s CY 2024 IPPS rule.
• Reinstate the PSI-90 composite measure or create a stand-alone quality measure for PSI-03, Pressure Ulcer Rates to maintain focus on pressure ulcers/injuries.
• Adopt as proposed and include in its final rule NQF #3992 the Global Malnutrition Composite Score.

The Coalition submitted comments to the CY 2021 proposed physician fee schedule. We:

• Recommended that CMS add codes for disposable negative pressure wound therapy (dNPWT) to the eligible telehealth list, 
• Opposed CMS failure to adopt ALL of the RUC recommended work and time values for the revised office visit E/M codes for CY 2021, including and especially the RUC’s recommendation of commensurately including the updated E/M values in procedure codes with 10 and 90 day global periods.

• CMS should not move forward with a final rule on payment methodologies for DMEPOS until further work is completed.
• CMS should work with stakeholder groups and experts outside of CMS to ensure that the agency has a sufficient understanding of all costs associated with the provision of wound care products and other various types of technology classified under the DMEPOS benefit.
• The Medicare “gap filling” payment determination methodology must be replaced as it is archaic, and does not result in reimbursement rates that allow access to medically necessary technology.
• Fee schedules developed through comparable technology or technology assessments should be transparent and should include manufacturer’s input to ensure a thorough understanding of all associated costs.
• CMS should institute an efficient and expeditious appeals process for manufacturers to challenge reimbursement levels established by this new pricing methodology and gap filling.
• HCPCS public meetings should be limited to input on HCPCS codes, which are universal and as such should be focused on needs of all payers.

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.

• 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).

• Mandatory education and training for all providers and Medicare contractors
• The creation of a process for interested stakeholders to challenge published case precedent
• The assurance that attorney adjudicators will have experience in Medicare coverage, coding, and payment and that those attorneys, too, receive continuous education and training on these issues.