American Society of Plastic Surgeons
For Consumers

FEDERAL | ASPS Comments on APM for Wound Care

ASPS recently submitted comments to the members of the Physician-Focused Technical Advisory Committee (PTAC) opposing the development of an Alternative Payment Model (APM) that positions physical therapists (PTs) and occupational therapists (OTs) at the forefront of clinical decision-making for wound care. While ASPS recognizes that these professionals are invaluable members of the wound care team, ASPS believes the wound-care model could unintentionally limit access to currently available advanced high-cost skin substitutes as well as potentially new, innovative skin substitutes that may be classified as high-cost. ASPS also noted the model inappropriately expands the scope of practice for PTs/OTs and, as written, would seem to prioritize cost of care to the detriment of clinical quality.

The proposal was one of five submitted to the PTAC in November. The PTAC is a committee of nationally recognized experts in the delivery of care and alternative payment models, created under MACRA. It is charged with assisting providers with the development of new APMS, for use in Medicare's Quality Payment Program (QPP). The committee's recommendations are shared with CMS, who makes final determinations on the types of APMs recognized under the QPP's MIPS and Advanced APM payment programs.

The PTAC will discuss the proposal, as well as any comments received at its next public meeting, scheduled for March 26, 2018 in Washington, DC.