APWCA collaborated with the Alliance of Wound Care Stakeholders in submitting a letter to the Centers for Medicare and Medicaid Services (CMS) flagging the differing interpretations of the three payment methodologies that CMS has been considering in HOPD / ASC proposed rule making regarding payment for skin substitutes / CTPs. We specified our understanding of each methodology and outlined issues to consider for each methodology. This was all done with advocacy for our members and our patients in mind.