Alliance of Wound Care Stakeholders
September 27, 2019

Comments to CY2020 Hospital Outpatient Prospective Payment System

The Alliance submitted comments to CMS addressing relevant wound care provisions in its CY2020 Hospital Outpatient Prospective Payment System. Comments flagged concerns and provided recommendations on a range of topics including:
  • The broad sweep to move all therapeutic services from direct to general supervision
  • The implementation of prior authorization for procedures that are often utilized to treat chronic wounds that threaten both life and limb
  • Payment methodologies for CTPs
  • Lump-sum episode based payment for a wound care episode
  • The single Ambulatory Payment Classification (APC) proposal and C-APC methodologies 
  • Inaccurate APC Group assignments for CTPs due to facilities' incorrect coding/billing, which for years has resulted in APC Group assignments that fail to reflect the true costs of the CTPs.

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