There has been significant pressure by all organized medical associations representing all stakeholders in this issue. This includes medical associations, wound care manufacturers and patient advocacy groups. It remains to be seen what action the CMS contractors will take. It is likley whatever action is taken it will be uniform as CMS is bent on cutting down on the abuse and escalating costs associated with CTPs. The recent OIG report certainly does not help.At this point the CMS contractors will either drop the entire issue as they have in the past, amend their initial draft policies or enforce their draft policies with no comment.My personal opinion is that they will take the signficant push back provided by medical providers seriously and either amend or drop the whole thing as they have before. They will then quickly adopt a new draft policy for comment.
It would be a shame for any policy to throw the baby out with the bath water (as the proposed policy does) simply because of the inappropriate fraud and abuse of a select number of providers. CTP are here to stay and they most certainly have saved limbs.But perhaps the science behind it must be more strictly adhered to by the mfgs and the HCPCS Common Work Group needs to seriously consider revamping its approval of new HCPCS code for new CTP.
There has been significant pressure by all organized medical associations representing all stakeholders in this issue. This includes medical associations, wound care manufacturers and patient advocacy groups. It remains to be seen what action the CMS contractors will take. It is likley whatever action is taken it will be uniform as CMS is bent on cutting down on the abuse and escalating costs associated with CTPs. The recent OIG report certainly does not help. At this point the CMS contractors will either drop the entire issue as they have in the past, amend their initial draft policies or enforce their draft policies with no comment.My personal opinion is that they will take the signficant push back provided by medical providers seriously and either amend or drop the whole thing as they have before. They will then quickly adopt a new draft policy for comment.
It would be a shame for any policy to throw the baby out with the bath water (as the proposed policy does) simply because of the inappropriate fraud and abuse of a select number of providers. CTP are here to stay and they most certainly have saved limbs.But perhaps the science behind it must be more strictly adhered to by the mfgs and the HCPCS Common Work Group needs to seriously consider revamping its approval of new HCPCS code for new CTP.