APWCA collaborated with the Alliance of Wound Care Stakeholders to submit comment to CMS’ Proposed CY2021 Hospital Outpatient Prospective Payment System. In these comments, we supported inclusion of synthetic CTPs in the definition of “skin substitutes” but expressed significant concerns with the Agency’s proposed establishment of the code C1849 (“Skin substitute, synthetic, resorbable skin substitute per square centimeter) to define an entire class of non- branded products and its placement in the OPPS high cost payment package. The Alliance reviewed the impacts of this code as proposed and submitted a number of alternative recommendations.

https://www.woundcarestakeholders.org/images/October_2020_Alliance_Comments_to_HOPPS_Final.pdf