Comments to Proposed 2024 Hospital Outpatient Prospective Payment System (HOPPS)

The Coalition submitted comments to CMS's proposed 2024 Hospital Outpatient Prospective Payment System (HOPPS) focused on the CTPs (skin substitutes) section of the proposed rule, flagging patient access issues as well as inconsistency in the way products are being treated in both payment and coverage depending on the HCPCS code being issued despite the products all being categorized as skin substitutes. The Coalition recommended that CMS withdraw its policy to package payment and instead utilize ASP +6 for all skin substitutes and publish all data in the pricing data file. "Given the mandatory submission of ASP for all skin substitutes, CMS should use the data that is already being provided to it to form the payment for any given skin substitute," the Coalition wrote. To address inequities in the current payment system that continue to create barriers to access, the Coalition elevated the following recommendations - each of which was endorsed by the Agency's Advisory Panel on Hospital Outpatient Payment:

1. assign the existing CPT® add-on codes (15272, 15276, 15274, and 15278) and HCPCS codes (C5272, C5276, C5274, and C5278) to appropriate APC groups allowing for separate payment; and issue an exception to separately pay for these add-on codes.
2. assign the CPT and HCPCS codes for the same size wound, regardless of anatomical location on the body, to the same APC groups.
3. assign all new CTPs with both Q and A HCPCS codes to the low-cost APC groups until a manufacturer provides cost information to CMS.
4. realign both the high-cost and low-cost application procedure codes to higher paying APC groups that reflect the current average sales prices of all CTPs.
5. not assign CTPs that are not in sheet form (e.g., gel, powder, ointment, foam, liquid, or injected) to any APC group.

Read Coalition Comments