Alliance of Wound Care Stakeholders Responds to CMS Proposed Policy Changes in 2023 Physician Fee Schedule: Changes Could Increase Amputations and Infection for Patients with Wounds, Restrict Access to Care, Impact Reimbursement
The Alliance of Wound Care Stakeholders (The Alliance), a leading voice for wound care advocacy and education to address public policy issues impacting patient access to care, alerted the Centers for Medicare and Medicaid Services (CMS) that changes to the way cellular and/or tissue-based products for skin wounds (CTPs, also known as "skin substitutes") are coded and paid for in the physician office under the proposed 2023 Physician Fee Schedule may have unintended consequences of creating barriers to care. Proposed reduced payments for CTPs would not match the costs to physician offices, making these products unaffordable and therefore, unavailable for medically necessary and successful advanced treatments ? potentially increasing amputations and infection for patients with chronic non-healing wounds.
"Our comments urge CMS to withdraw or delay implementation of the proposed CTP provisions from the final 2023 Physician Fee Schedule that will be issued this year, giving them the opportunity to further study patient access issues and assess policy implications vetted with key stakeholders," says Marcia Nusgart, R.Ph., CEO of The Alliance of Wound Care Stakeholders.
CMS' proposed policy reclassifies all CTPs as "supplies incident to a physician service," and packages payment for these "supplies" into the practice expense associated with that service.
"The impacts are significant to wound care providers and patients on several levels," says Nusgart, citing several problematic areas.
- Reclassifies CTP as "supplies," ignoring the therapeutic significance of CTPs and their longstanding treatment as biological products.
- Packaging payment for CTPs as "supplies" strips the very payment mechanism that currently allows these advanced therapies to be provided in the physician office.
- Creates access barriers at sites of service where outpatient facilities refer patients resulting in increased disparity of health outcomes for persons of color, individuals living in rural areas and others who do not have ready access to hospital inpatient care.
- Policy change is at odds with CMS' priority to address amputation avoidance.
"Our comments reflect the input and perspectives of our members -- thousands of clinicians and wound care stakeholders nationwide -- that decry this assault on patient access to care," says Nusgart.
About The Alliance of Wound Care Stakeholders
As the leading voice of wound care advocacy for the past 20 years, The Alliance unites leading wound care organizations and experts through advocacy and educational outreach in the regulatory, legislative and public arenas to advocate on public policy issues that may create barriers to patient access to treatments or care. With a key focus on coding, coverage and reimbursement, quality measures and wound care research, The Alliance has enabled the wound care clinical community to collaborate, elevating the visibility and united voice of wound care providers to regulators and policymakers. For more information visit www.woundcarestakeholders.org
See The Alliance's full comments here.
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