The Alliance submitted comments to CMS' proposed CY 2023 Hospital Outpatient Prospective Payment System expressing significant concerns with several provisions within the "skin substitute" section of the proposed rule. In its detailed feedback to CMS, the Alliance:  

• Opposed CMS' renaming the term "skin substitutes" to "wound care management products."
• Opposed CMS' proposal to change CTP's HCPCS codes from “Q” codes to “A” codes (supply codes). Called out some of the concerning cross-over issues from the proposed 2023 Physician Fee Schedule and recommended that the Agency publish ASPs and continue to accept ASP pricing for inclusion in payment methodology for all CTPs in order to achieve savings and consistency.
• Urged CMS to remove patient access barriers by correcting inadequacies in CTP payments. The Alliance once again submitted the recommendation that CMS make policy updates to (1) Enable Provider-Based Departments to be reimbursed for an adequate amount of CTP products for larger wounds and (2) Equalize payment for the application of CTPs wounds of the same size, no matter where they are on the body.

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