CMS Policy Updates from the Alliance of Wound Care Stakeholders

Coverage and payment regulations from the Centers for Medicare and Medicaid Services (CMS) dictate which products and services wound clinics and wound care clinicians can provide to their patients, and at what reimbursement rate. This summer, CMS issued its annual proposed payment rates for the year ahead, which have potential impacts to coverage and reimbursement for wound care products and services.

The Alliance of Wound Care Stakeholders, an association representing 20+ clinical associations and physician specialty societies involved in wound care, is providing the following update on recently issued regulations:

•    Hospital Outpatient Payment. In July, CMS issued its proposed draft rule on CY 2022 Medicare Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System. While the regulation contains numerous payment rates, the provisions specific for cellular- and tissue-based products for wounds (formerly known as skin substitutes) are most relevant to the wound care community and will be the focus of comments and advocacy from the Alliance of Wound Care Stakeholders. The 60-day public comment period extends through September 17, 2021. The final rule is expected to issue in November.

•    Physician Fee Schedule. In July, CMS issued its proposed 2022 Medicare Physician Fee Schedule, which announces and solicits public comments on proposed policy changes for Medicare payments, as well as—importantly—updates to the Quality Payment Program (QPP). Most relevant to wound clinics and wound care providers are provisions related to payment for “synthetic CTPs,” cuts to surgical procedures, a reduction in fees for disposable negative pressure wound therapy, and expansions of Medicare telehealth services beyond the COVID-19 Public Health Emergency. The Alliance will be focusing its comments on these areas. Public comments are due to CMS on September 13, 2021 and the final regulation is expected to publish in November.

Click here to learn more about the Alliance advocacy and its impact on CMS policies.