AHA, others urge CMS to ensure ACOs, MIPS-eligible clinicians are protected from increased skin substitute spending

A coalition of organizations, including the AHA, urged the Centers for Medicare & Medicaid Services to ensure accountable care organizations and Merit-based Incentive Payment System-eligible clinicians are held harmless from increased billing for skin substitutes. The organizations said that while some of the spending originates from appropriate wound care, evidence suggests much of it represents wasteful or fraudulent activity. In addition, the organizations said that trend adjustments in the Medicare Shared Savings Program, Accountable Care Organization Realizing Equity, Access, and Community Health Model, and the Comprehensive Kidney Care Contracting Model do not adequately account for increased skin substitute billing. “Ultimately, this situation leaves the clinicians in these models financially accountable for improper billing,” the organizations wrote. “Similarly, physicians participating in MIPS will be penalized on the MIPS cost measures due to aberrant and potentially wasteful, fraudulent, or abusive spending on skin substitutes.” 

Members of Congress also urged CMS to take similar action on skin substitute spending.