HCPCS Coding Reform Advocacy

The current Healthcare Common Procedure Coding System (HCPCS) coding process for Level II alpha-numeric codes used by Medicare, Medicaid, and commercial health plans (particularly for durable medical equipment, orthotics, prosthetics and supplies [DMEPOS]) is not transparent, understandable or predictable.

Over many years, this has created strong barriers to appropriate coverage and reimbursement for new technologies and products. 

The current process has had a chilling effect on innovation that drives researchers and R&D investments away from DMEPOS, ultimately compromising access to quality care for millions of Medicare beneficiaries and other individuals. Although this process is administered by the Centers for Medicare and Medicaid Services, this badly flawed process impacts Medicare and all payers using the uniform code set.

Advocate for Reforms

Nusgart Consulting not only provides manufacturers with strategic guidance to submit and navigate HCPCS coding applications, but we can also assist interested manufacturers to have a voice in advocating for reforms to ensure the goals of a meaningful code set are met:  uniformity in billing, appropriate coverage and reimbursement policies, and patient access to quality care.

To this end, Marcia Nusgart led efforts to form the Alliance for HCPCS II Coding Reform, which focuses on advocacy to elevate the need for HCPCS coding reform to ultimately help improve patient access to medically necessary products and simplify the process for manufacturers to bring products to the wound marketplace.  The Alliance pens letters to senior HHS officials and Capitol Hill, testifies at relevant public meetings and has convened meetings with the HHS Secretary, CMS Administrator, senior CMS staff and MEDPAC staff on this topic. Marcia Nusgart and the Alliance for HCPCS II Coding Reform work to voice shared industry, provider and patient concerns with the current coding process and asking CMS to:


Marcia has also led advocacy with CMS and PDAC leadership on some of the issues surrounding the HCPCS coding verification application and process. Her work mobilizing aligned stakeholders and advocating to senior PDAC leadership has driven updates, simplifications, and improvements to the process that will benefit all future industry application.

Connect with Nusgart Consulting to explore how you can play a role in HCPCS coding reform advocacy.  Learn how Nusgart Consulting’s expertise in this area can benefit your products and your company.