The Alliance submitted recommendations  regarding payment methodologies for cellular and/or tissue based products for skin wounds (CTPs) for the Agency to consider prior issuing proposed rulemaking for Calendar Year 2021.The Alliance highlighted that there are many differing interpretations of the three payment methodologies that CMS has been considering: Episodic Payment, Single APC, and Comprehensive APC. The Alliance outlined its  understanding of each methodology, and sought to clarify if its definitions and interpretations were correct.

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