Comments to proposed 2023 Physician Fee Schedule

The Coalition's submitted comments to CMS's 2023 Physician Fee Schedule adamantly oppose the  proposed policy changes to the way skin substitutes (CTPs) have been coded and reimbursed in the physician’s office for over 30 years by reclassifying skin substitute products as supplies and paying for them as part of the practice expense relative value units (RVUs) for the procedure with which they are used. These seismic changes will lead to significant limitations on the access to care for numerous patient populations including but not limited to: minorities, patients in rural areas and patients with diabetes, the Coalition told CMS. This decrease in access to care may result in the likelihood of increased infection and amputations for these patients. The Coalition urged CMS to remove the provisions or, at very least, to delay the implementation of these provisions until more clarity is provided.
Read Coalition Comments