September 9, 2024
Comments to proposed 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS)
- CTPs/Skin Substitutes: The Alliance once again forwarded recommendations that CMS’s own HOPPS Advisory Panel has endorsed year after year: that CMS update provisions to (1) Enable provider-based departments to be reimbursed for CTP product for larger wounds by paying separately for select add-on codes; (2) Equalize payment for the application of CTPs on wounds/ulcers regardless of anatomic location under a consistent APC code, and (3) Place all new CTPs with "Q" or "A" HCPCS codes in low-cost APCs, unless or until a manufacturer provides CMS with cost data suggesting otherwise. The Alliance's submission to CMS flagged many deficiencies/inaccuracies in the Agency’s “response to comments” that CMS published as rationale for not adopting these previously suggested changes. The Alliance provided correction and clarity on the "response to comments" to further advance CMS consideration of these recommended policy updates.
- Total Contact Casting (TCC): The Alliance requested that CMS again follow the endorsement of its HOPPS Advisory Panel and pay hospital outpatient departments a separate APC for the TCC (APC 5102) when a debridement or graft is performed on the same date of service – something currently denied because of an inaccurate NCCI edit that has been put in place. The Alliance re-forwarded its and the Panel's recommendation that CMS consider HCPCS code 29445 (Application of rigid total contact leg cast) a separately payable code when performed concurrently on the same date of service as select HCPCS codes related to debridement and skin substitute grafts so that facilities can be paid for this separately identifiable service that is not included in the debridement or application of CTPs, and patients can recieve this care.
- Alliance comments also addressed provisions on Blood and Blood Derived Products, Telehealth and Prior Authorization.
See the Alliance’s full comments below.
