September 5, 2023

Last week, APMA submitted comments to CMS in response to its proposed rules related to the Home Health Prospective Payment System (HHPPS) and Transitional Coverage for Emerging Technologies (TCET).

In the comments related to the HHPPS proposed rule, APMA focused largely on CMS’ proposal to create a new benefit category for “lymphedema compression treatment items.” APMA was generally supportive of CMS’s proposals related to this section. We also strongly recommended that CMS should make the professional services of applying these types of bandages a covered service, and supported finalizing CMS’ proposal to include accessories necessary for the effective use of gradient compression garments and gradient compression wraps with adjustable straps under this new benefit for lymphedema compression treatment items.

In the comments related to the TCET, APMA supported CMS’ revamped proposal to meaningfully create a new mechanism that would allow temporary Medicare coverage to certain qualifying devices designated by the Food and Drug Administration (FDA) as breakthrough devices, via the transitional coverage for emerging technologies (TCET) pathway. APMA recommended that CMS provide clearer guidelines for how it will prioritize nominations for acceptance into the TCET pathway. We also recommended that CMS provide additional clarification on how coding and payment processes to facilitate coverage and payment for new or emerging technologies will unfold.

To read both these letters and other past letters in full, visit www.apma.org/CommentLetters. Contact the APMA Health Policy and Practice department with any questions or concerns.

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