Advocacy Accomplishments
The Alliance's impact in 2024 was extensive.
as a result of our tenacious advocacy, we:
- Enabled wound care providers using CTPs to have application flexibility, an extended episode of care, and an expanded timeframe to implement the final CTP local coverage determinations (LCDs) published in November by successfully advocating the Medicare Administrative Contractors to remove arbitrary CTP application limitations and incorporate substantive stakeholder input in the final policies. The final policies included considerable improvements to the clinical practice limitations included in the proposed policies issued for comment in April 2024 and now better protect quality patient care and evidence-based treatment with CTPs in DFU/VLU.
- Mobilized establishment of a national reimbursement rate for blood-derived products for use in chronic diabetic wounds to better reflect complexity, time, and costs in the 2025 Physician Fee Schedule. Successfully attained an update to the rate proposed in the draft policy so that it was increased in the final rule to better reflect the true cost of care delivery.
- Attained key “fixes” to surgical dressings claims processing issues that were impacting access. Identified issues, compiled examples and educated DMEMAC medical directors about issues, mobilizing them to review and adjust claims processing system to fix inconsistent surgical dressings claim denials and make updates to address maximum allowed surgical dressing quantities per patient/per month with multiple wounds.
- Achieved update to DMEMAC surgical dressings policy article that was causing systematic denials and challenging access for patients with multiple wounds. Drafted by the Alliance and forwarded to the DMEMACs for consideration, the language published in February 2024 policy article update clarifies surgical dressing modifier quantity limitations, facilitating coverage and payment for surgical dressing application to a second wound.
The Alliance shaped policy development in 2024 as we:
- Led advocacy seeking withdrawal of FDA’s proposal to reclassify hundreds of antimicrobial wound products to class III, elevating the FDA the policy’s many ambiguities and flagging it would result in the unnecessary removal of many important products from the market - which could result in clinicians using more antibiotic products and exacerbating the very resistance problems the Agency is trying to address.
- Escalated concerns with the episode-based cost measure being developed for non-pressure ulcers via a series of letters, comments and conversations flagging flaws in the field testing and the many ways the measure did not accurately capture the data necessary for a fair, reliable, accurate measure. The Alliance recommended that the proposed measure be withdrawn until further refinements were made and additional testing be conducted.
- Urged CMS to enable payment for clinicians to measure and fit lymphedema compression garments via an ongoing advocacy initiative of letters, comments and meetings to keep focus on this issue.
- Gained HOPPS Panel support of the Alliance’s recommendation to fix flawed total contact casting payment with a separately payable APC code for TCC when performed on the same date of service as a debridement and/or the application of CTP – removing a barrier that inconveniences patients and providers by preventing these treatments from being performed on the same date of service.
- Pursued update to DMEMAC LCD to establish coverage of topical oxygen therapy for diabetic foot ulcer.
- Proactively advanced CTP payment methodology recommendations focused on ASP pricing as CMS continues to internally consider and vet its payment approach to this category of products across sites of care.
- Maintained focus the important role of real-world evidence in wound care research and the importance of FDA/CMS dialogue to move forward.
Over 2024, the Alliance developed and submitted 26 comments to regulators, elevating perspectives and recommendations from the wound care community in policy development. Our progress and successes are a testament to the strength, power, and influence of having a unified - and tenacious - voice for wound care advocacy. Learn more in the Alliance's 2024 annual report (soon to be released).
See how we've been driving change and moving wound care forward for the past 20 years:
For information on accomplishments of previous years, see below:
