September 12, 2022

APMA submitted comments in response to CMS’ proposed changes to the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System proposed rule for 2023. APMA’s comments focused on the following concerns:

• Wound Care Management Terminology. APMA disagrees with CMS that “skin substitutes” should be renamed “wound care management products.” CMS has indicated that the reason for the change of nomenclature is to provide a “more accurate and meaningful term,” to help address confusion among interested parties about how these products are described and how they are paid. APMA recommends that CMS adopt the term “Cellular and/or Tissue Based Products for Skin Wounds” or CTPs, in order to create less confusion and to utilize a more accurate term describing the entire suite of products currently marketed as well as prospective ones. This nomenclature is already known and being utilized by clinicians and speakers at conferences, as well as in publications and several of the CMS A/B MAC contractors and private payers’ LCDs.
• Elimination of HCPCS Q Codes to Designate CTPs. APMA opposes the HCPCS CTP coding changes from Q codes to A codes. A codes designate supplies, but CTPs are not supplies. In making the current proposals, CMS fails to recognize that a majority of these products are in fact biologicals. Transitioning to A codes does not capture the therapeutic significance of these treatments. Therefore, APMA recommends that all CTPs be assigned a Q code when meeting the requirements of HCPCS.
• Opportunities within CMS Quality Programs. CMS may spend as much as $98 billion a year on treatment of chronic wounds, impacting 15 percent of Medicare beneficiaries. However, there are no national MIPS quality measures relevant to the management of patients with chronic wounds and ulcers, and among the quality programs in all health-care sectors, there is only one measure relevant to chronic wounds (the counting and staging of pressure injuries).  CMS has acknowledged that rates of amputation have accelerated during the PHE, due in part to delayed wound care and preventive care. APMA believes that without appropriate coverage of preventive care, this situation will continue. APMA believes that ulcer risk assessment and follow-up are key components of preventive care for patients with diabetes, including use of APMA’s Comprehensive Diabetic Lower Extremity Exam Model.

Read the full letter at www.apma.org/commentletters. Contact the APMA Health Policy and Practice Department with any additional concerns or comments.