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The Centers for Medicare and Medicaid Services (CMS) has issued the final rule for the 2023 Physician Fee schedule

  • CMS IS NOT finalizing the payment approach outlined in the proposed rule in which they proposed to make Cellular and/or tissue-based products (CPTs) part of the physician overhead expense
  • CMS is also not changing the name “skin substitutes” to “wound management products “at this point in time.
  • Instead of taking action now, CMS will conduct a Town Hall with interested parties in early 2023 to discuss alternative potential payment approaches for skin substitute products prior to 2024 rulemaking.

Read the details for yourself here:

I suspect that CMS was surprised by the response they received to the proposal from clinicians and specialty societies. It’s a huge win for the Alliance of Wound Care Stakeholders which lead the way in the response. We have to be realistic that some changes have to be made by CMS in 2024, and I hope CMS and the clinical organizations will focus on how to ensure that there is appropriate use of these products. For example, a few years ago, CMS approved a quality measure focused on “The Appropriate Use of CTPs for Diabetic foot ulcers,” but then rejected it after about two years due to lack of reporting. It’s understandable why an “appropriate use” quality measure wasn’t reported for CTPs– why report a measure if you don’t have to? However, if we can’t find a way to ensure appropriate use of CTPs, CMS will have to reduce access to CTPs for everyone. I hope we can find a way forward.

–Caroline

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