The Physician Fee Schedule proposed rule is out. Remember that like the OPPS proposed rule, there’s a comment period and possible changes before this is finalized. Here are the links you need to read things yourself. CMS is inviting comments on all these proposals and it is easy for you to make your voice heard during the comment period:
I will be inviting guest blogs from various experts to discuss the implications of some of the CMS proposals impacting wound care. You should read the proposed rule yourself because there is language around:
- Non-sheet CTP payment (proposal to pay at the same rate as those CTPs in sheet form)
- Autologous blood derived products (misvalued application code was denied)
- Hyperbaric oxygen therapy billing: Bottom line is that it would stay the same with the “facility” fee continuing to be billed in 30 minute increments and the physician supervision payment as once per treatment.
- Skin Cell Suspension Autograft CPT codes
- Real-time Fluorescence Wound Imaging (CPT code 976XX) payment (there’s a lot to unpack here)
- Ultrasonic Wound Assessment (CPT code 97610) – Also a lot to unpack but bottom line is a proposed reduction in payment for supplies
- CMS added a podiatry MIPS Value Pathway which includes measures related to wound care. (Stay tuned for a LOT more on this since 3 US Wound Registry quality measures are included)
- USWR33: Diabetic Foot Ulcer (DFU) Healing or Closure
- USWR34: Venous Leg Ulcer (VLU) Healing or Closure
- USWR35: Adequate Off-loading of Diabetic Foot Ulcers performed at each visit, appropriate to location of ulcer
- Related to the above: CMS proposes sunsetting traditional MIPS by 2029 and moving toward MIPS Value Pathways (MVPs). CMS proposes three new MVPs in diabetes, hypertension, and hospital-based care. [Note: The proposed transition to MVPs is NOT new, but the implications of an MVP for diabetes is a big one. CF]
- RFI on CPT: CMS is seeking stakeholder feedback on the role of the AMA CPT coding system and RUC in Medicare physician payment, including potential alternatives to the current coding and 2 valuation process. CMS requests comment on the impact of CPT licensing, the development of CPT codes, and alternative approaches to coding and valuing physician services.
Caroline
Dr. Fife is a world renowned wound care physician dedicated to improving patient outcomes through quality driven care. Please visit my blog at CarolineFifeMD.com and my Youtube channel at https://www.youtube.com/c/carolinefifemd/videos
The opinions, comments, and content expressed or implied in my statements are solely my own and do not necessarily reflect the position or views of Intellicure or any of the boards on which I serve.
