October 5, 2020
Comments to CMS Proposed CY2021 Hospital Outpatient Prospective Payment System
The Coalition submitted comments to CMS' Proposed CY2021 Hospital Outpatient Prospective Payment System. Our comments primarily focused on the provisions relating to synthetic CTPS, and we urged CMS to:
- Eliminate the new code C1849 ((“Skin substitute, synthetic, resorbable skin substitute per square centimeter) as it is inappropriate and not consistent with the coding for any/all other CTPs,
- Remove placement of the C1849 synthetic CTP products from the high cost tier,
- Require any synthetic CTP to apply for an appropriate HCPCS Q code to be considered a CTP.
