The Alliance submitted comprehensive comments to CMS’ proposed CY 2025 Medicare Physician Fee Schedule (CMS- 1807-P). Alliance comments and recommendations focused on a range of provisions impacting wound care, including:

• National payment for autologous blood-derived products (HCPCS code G0465): The policy included national pricing for this product category  but at an inadequate payment rate that would challenge clinicians’ ability offer these treatments and perpetuate access issues. The Alliance urged CMS appropriately account for the current cost and professional time and effort required to deliver these  wound care treatments. To address this the Alliance recommended that CMS:
  • Change the proposed CPT skin substitute-aligned crosswalk codes to more clinically aligned and appropriate epidermal & dermal autograft codes;
  • Include appropriate RVUs for debridement in the total RVU calculation for G0465 (or clarify that debridement can be billed separately if it is not included); and
  • Remove provisions restricting a provider from billing for more than one unit of G0465 per day so that patients with multiple foot wounds can to be treated.
• CTPs/skin substitutes for skin wounds: The Alliance urged CMS to:
  • Adopt a universal ASP reimbursement methodology for all CTPs - under both “Q” & “A” HCPCS codes;
  • Use the Agency’s full enforcement authority to ensures it receives complete ASP data from manufacturers, including discounts and rebates; and
  • Publish all ASPs for CTP products in the pricing data file, which ultimately could mitigate the concerns that are driving CMS to consider disruptive payment approaches such as bundling.
• Physician Payment Cuts: The Alliance flagged that the proposed 2.8% conversion factor reduction fails to support clinicians and encouraged CMS to work with Congress to ensure that payments to clinicians are adjusted each year with an inflationary update.
• MIPS Value Pathway: The Alliance sought CMS feedback and collaboration on the potential creation of a Chronic Wound Management MVP that could make it possible for the many different types of practitioners involved to collaborate in such a way as to properly associate quality and cost.
• Physical therapy assistant supervision: The Alliance supported the change in supervision requirement from direct to general, consistent with the standards applied in nearly all settings paid under Medicare.
• Alliance comments also addressed provisions related to caregiver training services,  telehealth, the Medicare Diabetes Prevention Program, and the global surgery package.

See the Alliance's full comments below. 

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