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FEDERAL | ASPS Submits Comments on HOPPS Proposed Rule

Since 2014, the Centers for Medicare & Medicaid Services (CMS) has categorized skin substitutes billed under the Hospital Outpatient Prospective Payment System HOPPS as either a "high" or "low" cost device, based on a complicated formula that includes averaging the "mean unit cost" of a product. Yearly updates to the formula created significant variations in payment policy, as well as total reimbursement from year to year for procedures that include skin substitutes. Thanks to the advocacy efforts of ASPS and other medical society societies, the Agency indicated its willingness within the recently released proposed rule to limit year-to-year fluctuations in the reimbursement formula for skin substitutes in 2018 while further study of the issue takes place.

ASPS thanked CMS for making this important update. The September 11th letter also repeated the Society's concern that without specific edits to alert physicians that they need to report packaged skin substitutes when appropriately provided during a surgical procedure, the Agency will continue to make reimbursement decisions based on faulty data. ASPS encouraged the Agency to develop claim edits as well as educational materials to alert providers of the need to report skin substitutes and to develop web-based learning modules to provide information on how a standardized reporting process for skin substitute products can help provide stability in the reimbursement calculations of surgical procedures that frequently require skin substitute products.

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