The Tribal Consortium’s Authorized Tribal Agent, Clear Health Pass Holdings, joined a working session with CMS Drug Pricing and the Coverage and Analysis Group to address the Average Sales Price submission and HCPCS code record for Rampart™ DL Matrix (Q4347).

The session — convened by Maria Durham of CMS Drug Pricing and joined by Prabath Malluwa-Wadu, Syed Shirazie, Laura Kennedy, and CAPT Susan Karol — addressed three technical matters: confirmation of the Q-code product description for Rampart™ DL Matrix, expansion of the Medically Unlikely Edit limit to align with clinical practice for advanced wound care, and proper ASP reporting under Section 303 of the Medicare Modernization Act.

The work was substantive and collaborative. Two days earlier, the Consortium had filed a formal MUE Expansion request through the proper CMS channel. Twelve days later, on June 24, CMS confirmed that the CHP/BLREDCO ASP Corrections had been filed for HCPCS code Q4347 — “Rampart DL Matrix, per square centimeter.” Each step occurred through the agency’s preferred process, with the agency’s preferred personnel, on the agency’s preferred timeline.

“This is the part of federal engagement that rarely makes the news, but it matters. Getting the Q-code description right, getting the ASP record clean, getting the MUE limits aligned with how wound care is actually practiced — those are the details that determine whether a provider in Indian Country can actually use this product to treat a patient. Maria Durham, Prabath Malluwa-Wadu, and their colleagues did the work with us. We’re grateful for that, and we say so publicly.”

— John Michael Cataldi, CEO, Clear Health Pass Holdings

What this means for tribal health and tribal nations

The technical integrity of the federal record is what makes clinical access real. When the Q-code description is wrong, claims get denied. When the MUE limit is too low, wounds go undertreated. When the ASP record has gaps, providers can’t bill accurately and patients lose access to advanced therapies. The June 2025 sessions corrected all three — a quiet outcome with direct consequences for tribal members and all Medicare beneficiaries with chronic wounds.

About Clear Health Pass™  

Clear Health Pass™ is a bioinformatics, bio-surveillance. Clear Health Pass™ is a minority/veteran-operated organization in partnership as tribal is a portfolio partner of The Native American Venture Fund (NAVF). Clear Health Pass Holdings, LLC, DBA Clear Health Pass™ is an appointed “Tribal Agent” for The Tribal Consortium, a federal, Section 17 Tribal Corporation, whose tribal sovereignty’s authority is derived from The Indian Reorganization Act Of 1934 (IRA), 25 U.S.C. § 477. If you would like to know more information and investment opportunities with Clear Health Pass™ you can request information via this link

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