CMS Looks to Make Changes on Codes for Skin Wounds

The Centers for Medicare and Medicaid Services is looking to change the way cellular and/or tissue-based products (CTPs) for skin wounds are coded and paid for in the physician office under the proposed 2023 Physician Fee Schedule.

CMS’ proposed policy reclassifies all CTPs as “supplies incident to a physician service,” and packages payment for these “supplies” into the practice expense associated with that service.

CMS proposes to replace the term “skin substitutes” with the term “wound care management” so skin substitute products that were previously assigned Q codes will continue to be paid under the current Average Sales Price (ASP)+6 payment methodology. However, effective starting CY 2024, these products would be considered incident to supplies.

Accordingly, CMS proposes to discontinue Q codes at the end of CY 2023 and establish “A” codes for all skin substitute products meeting the criteria for a HCPCS Level II code, and to contractor price these codes effective Jan. 1, 2024.

Some argue the proposed changes may have unintended consequences of creating barriers to care. For instance, the Alliance of Wound Care Stakeholders, a leading voice for wound care advocacy and education to address public policy issues impacting patient access to care, could cause unforeseen problems.

Marcia Nusgart, CEO of the alliance, notes that the proposed reduced payments for CTPs would not match the costs to physician offices, so the products would be unaffordable to most resulting in being unavailable for medically necessary and successful advanced treatments, thereby potentially increasing amputations and infection for patients with chronic non-healing wounds.

“We urge CMS to withdraw or delay implementation of the proposed CTP provisions from the final 2023 Physician Fee Schedule that will be issued this year, giving them the opportunity to further study patient access issues and assess policy implications vetted with key stakeholders,” Nusgart says. “The impacts are significant to wound care providers and patients on several levels.”

Among the reasons she cites are packaging payment for CTPs as “supplies” does away with the positive payment mechanism that now allows these advanced therapies to be provided in the physician office; ignores the therapeutic significance of CTPs and their longstanding treatment as biological products; and has a social determinant of health component, as it creates access barriers at sites of service where outpatient facilities refer patients resulting in increased disparity of health outcomes for persons of color, individuals living in rural areas and others who do not have ready access to hospital inpatient care.