The Alliance submitted comments to CMS on the proposed CY2017 Physician Fee Schedule. Comment focused on:

The under estimation and erroneous valuation of 2 CPT codes: CPT 29580 (Strapping of Unna Boot), and CPT 29581 (Application of multi-layer compression system).

Supporting the decision to update the equipment items and the amount of oxygen for hyperbaric oxygen therapy (HBOT) so that the amount of oxygen conforms to the RUC recommended value.

Requesting national payment rate for CPT Codes 97607 and 97608 - describing negative pressure wound therapy (NPWT) services using a disposable device - similar to the rate proposed in the CY2018 hospital outpatient proposed rule.

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 Alliance 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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