APMA Pushes Back on CMS' Flawed Skin Substitute Payment Proposal

APMA submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the proposed rule for Medicare and Medicaid Programs, Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center Payment Systems [CMS-1834-P]. APMA's comments focused on protecting patient access to skin substitutes, which are essential for the treatment of complex wounds such as diabetic foot ulcers.

CMS has proposed establishing a single payment methodology for skin substitute products, including an initial rate of $125.38 per cm². APMA opposes this approach because it is based on a biased and unsound methodology. The proposed rate is too low and would limit access to the most effective products for Medicare beneficiaries.

In addition, APMA raised concerns with CMS' plan to bring skin substitutes into the Medicare Physician Fee Schedule (MPFS). APMA emphasized this could be destabilizing and jeopardize patient care.

APMA provided CMS with the following recommendations:

• Abandon the flawed methodology used to set payment rates and instead consider alternatives that incorporate utilization and pricing data from both physician offices and the hospital outpatient setting.

• Pursue policies consistent with its current proposal to allow separate payment for skin substitutes under the Medicare Hospital OPPS. This would ensure continued patient access.

• Work with stakeholders and Congress to develop a more reasonable, evidence-based payment methodology that safeguards access to skin substitutes for Medicare beneficiaries.

APMA will continue to work closely with CMS, policymakers, and coalition partners to advocate for a fair, sustainable payment system that ensures our patients receive the care they need.

Read all advocacy comment letters at https://www.apma.org/commentletters. Contact the APMA Advocacy Department with any questions, concerns, or feedback.