September 11, 2017
Comments to CMS on the proposed CY 2018 Hospital Outpatient Prospective Payment System
The Coalition submitted comments to CMS on “CMS 1678-P, the Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs.” Coalition comments addressed:
- Issues with the methodology for packaging of skin substitutes (Cellular and/or Tissue Based Product for Skin Wounds, or CTPs)
- Support for grandfathering in eight CTP products to the high-cost bucket of the newly established threshold between low and high costs
- Request for CMS to work with stakeholders to obtain the proper data for creating appropriate APCs for the application of CTP products.
- In response to CMS’s request for information on flexibility and efficiency opportunities to increase care, reduce costs and reduce burdens for clinicians and patients, the Coalition asked the agency to consider reform of the process it uses to assign new Healthcare Common Procedure Coding System (HCPCS) Level II billing codes to durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS).
