2019 OPPS proposed rule: CMS seeks comment on skin substitute model changes

In the 2019 OPPS proposed rule, CMS does not introduce a new skin substitute payment policy but is seeking comment on potential changes for future rulemaking.

CMS intends to continue its policy of categorizing skin substitute products into high- and low-cost groups and will assign the items based on either a product’s geometric mean unit cost (MUC) exceeding the geometric MUC threshold or the product’s per-day cost (PDC)—the total units of a skin substitute multiplied by the MUC and divided by the total number of days—exceeding the PDC threshold.

However, as skin substitute manufacturers have raised concerns about significant fluctuations in both the MUC and PDC thresholds from year to year, CMS is considering several alternate models and specifically asks for feedback for 2020 rulemaking.

Those models include:

• Allowing for the payment of current add-on codes or creating additional procedure codes to pay for skin graft services between 26 sq. cm and 99 sq. cm and substantially over 100 sq. cm.

• Eliminating the high- and low-cost categories and only have one payment category and set of procedure codes for all skin substitute products
• Establishing a lump-sum “episode-based” payment for a wound care episode
• Keeping the high- and low-cost skin substitute categories, but changing the threshold used to assign skin substitutes in the groups

To learn more about the rule’s proposals and how they could affect your facility, attend HCPro’s annual OPPS proposed rule webinar on Tuesday, August 14, with Jugna Shah, MPH, president and founder of Nimitt Consulting Inc., and Valerie A. Rinkle, MPA, lead regulatory specialist and an instructor for HCPro Medicare boot camps.