Comments

Items Related to Physicians Fee Schedule

September 11, 2023

Comments to draft 2024 Medicare Physician Fee Schedule

The Coalition submitted comments to CMS' proposed 2024 Medicare Physician Fee Schedule voicing opposition to the Agency's proposal to treat CTPs (skin substitutes) as “incident to supplies” when furnished in non-facility settings and to include the costs of these products as resource inputs in establishing practice expense RVUs for associated physician’s services, rather than reimburse them separately. The Coalition outlined specific concerns, requested that CMS withdraw the proposal, and recommended instead that CMS maintain and enforce ASP pricing – "the most consistent pricing for CTPs that should and can be utilized across payment settings."
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September 11, 2017

Comments to CMS on the proposed CY 2018 Physician Fee Schedule

The Coalition submitted comments to CMS on “CMS 1676-P: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2018.” The Coalition comments requested that CMS consider establishing office-based PE RUV’s for disposable Negative Pressure Wound Therapy (dNPWT). Comments also noted issues with codes and payment rates for NPWT services. The Coalition recommended that CMS assign direct cost inputs to disposable negative pressure wound therapy, which would allow the establishment of national payment rates for CPT codes 97607 and 97608 in the final Physician Fee Schedule (PFS) rule for CY 2018. 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).
View Coalition Comment

December 25, 2016

Comments to CMS on Interim Final Rule with Comment Period on Hospital Outpatient Prospective Payment Systems (OPPS)

The Coalition submitted comments to CMS on the Interim Final Rule for the Hospital Outpatient Prospective Payment Systems, CMS-1656-IFC. The Coalition states that under this payment model, hospitals would lose the ability to provide cellular/ tissue based products (CTPs) and Negative Pressure Wound Therapy (NPWT) products to patients. The Coalition recommends that CMS reconsider their choice to adopt the Medicare Physicians Fee Schedule (MPFS) so that hospitals may have the ability to provide NPWT and CTP products.
view coalition comment

December 26, 2014

Comments

Items Related to Physicians Fee Schedule

Comments to draft 2024 Medicare Physician Fee Schedule

Comments to CMS on the proposed CY 2018 Physician Fee Schedule

Comments to CMS on Interim Final Rule with Comment Period on Hospital Outpatient Prospective Payment Systems (OPPS)

Comments to CMS on CY 2015 Physician Fee Schedule Final Rule

Comments to CMS on the CY 2015 Physician Fee Schedule

Comments to CMS regarding Negative Pressure Wound Therapy G codes as part of the Physician's Fee Schedule

Comments to CMS on the Physician's Fee Schedule

Coalition comments to CMS on the Physician Fee Schedule

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