Submitted Comments
January 17, 2025
The Alliance submitted comments to CMS' Medicare Managed Care proposed ruleCMS' Medicare Managed Care proposed rule supporting the Agency's provisions to improve Prior Authorization processes, while encouraging additional provisions to ensure MCO accountability are still needed. Only when payers are held accountable will the proposed changes to PA be a success for health care providers and the beneficiaries they are treating.
December 27, 2024
The Alliance submitted comments to CMS and the Partnership for Quality Measurement’s Pre-Rulemaking Measure Review Committee reiterating that we do not support the Non-Pressure Ulcers Episode-Based Cost Measure as currently proposed. The letter again articulated our many concerns – which were previously raised in prior comment letters, in meetings with Acumen staff, and most recently as part of our oral statement at the December Pre-Rulemaking Measure Review (PRMR) Listening Session. The Alliance recommended that the measure be withdrawn until further refinements are made and additional testing can be conducted with results provided to the Clinical Expert Workgroup for further discussion.
December 23, 2024
The Alliance, in collaboration with Epstein Becker Green, submitted a letter to CMS seeking important clarification on the 2025 Medicare Physician Fee Schedule Final Rule provisions setting a national reimbursement rate for autologous blood-derived products. The letter posed questions regarding billing for autologous blood-derived products (HCPCS code G0465) when multiple wounds are being treated, or when a wound with a large surface area requires more than one application of an autologous blood-derived product to treat the wound. The Alliance offered suggestions for N Medicare Learning Network (“MLN”) Matters article AND updates to the Medicare billing guidance for G0465 to better clarify for providers how multiple applications of an autologous blood-derived product should be appropriately identified on the CMS-1500 claim form and how Medicare payment will be made for such multiple applications.
December 22, 2024
The Alliance submitted a letter to the DMEMAC medical directors elevating procedural concerns, potential improper voting processes, and technical delays that resulted in inadequate time for meaningful discussion of new evidence at the December Carrier Advisory Committee (CAC) meeting convened to discuss requests to revise the Oxygen and Oxygen Equipment Local Coverage Determination (LCD) to include language that Topical Oxygen is reasonable and necessary for wound healing therapy for treating Diabetic Foot Ulcers.
December 17, 2024
The Alliance presented at the Pre-Rulemaking Measure Review (PRMR) 2024 Measures Under Consideration Clinician Measures Listening Session, reiterating to Acumen and its expert panel that the Alliance does not support the Non-Pressure Ulcers Episode-Based Cost Measure as it is currently written. Similar to our prior letter to Acumen, our statement at the December 17th meeting flagged specific concerns with Acumen’s field testing of the current measure, including: an attribution methodology that incorrectly attributes costs; errors in diagnosis codes and ulcer categories that resulted in the cost for each ulcer category to be incorrectly calculated; and dramatic variations and discrepancies in calculations with no explanations provided. The methodology is so fatally flawed, we emphasized to Acumen in our statement, that the cost measure should not be utilized as it will not only be unsuccessful - it will be detrimental to clinicians.
December 10, 2024
The Alliance delivered oral testimony at the Dec. 10 Multi-MAC Town Hall Meeting and listening session on the final local coverage policies on CTPs for the treatment of Diabetic Foot Ulcers and Venous Leg Ulcers. The Alliance posed several specific questions regarding scenarios for multiple wounds as well as number of applications, as well as pursued clarification of reconsideration timelines and processes for manufacturers to submit new evidence for coverage.
November 23, 2024
The Alliance submitted comments to CGS Administrators proposed LCD “Non-Invasive Vascular Studies" (DL34045), flagging areas of the policy that are not reflective of current practice or standards of care. Comments addressed a range of issues in the wording of the policy including: inconsistencies in the descriptions of providers permitted to order/perform non-invasive vascular studies, credentialing definitions, accreditation standards and documentation burdens.
October 4, 2024
The Alliance responded to CMS' Request for Information (RFI) issued in September to obtain stakeholder feedback on the potential consolidation of four Medicare Administrative Contractors (MAC) jurisdictions into two jurisdictions, as well as to obtain feedback on extending MAC contracts to ten years. In its response, the Alliance emphasized the need for improved CMS oversight and transparency in MAC operations as well as provided feedback on issues spanning staffing and staff training, care disruption concerns, Contractor Advisory Committee (CAC) engagement, evidence evaluation processes, provider communications, prior authorization, appeals, reconsideration requests, and more.
September 27, 2024
As part of the CAC (Contractor Advisory Committees) Engagement Coalition, the Alliance sent a co=signed letter to CMS' Coverage and Analysis Group that identified meaningful opportunities to improve the engagement of clinicians in local Medicare policy development. The letter elevated specific recommendations regarding how MACS could work more collaboratively with Contractor Advisory Committees (CACs) and other advisory panels and addressed bringing more transparency and stakeholder input into the development of local coverage and payment policies.
September 9, 2024
The Alliance submitted comprehensive comments to CMS’ proposed CY 2025 Hospital Outpatient Prospective Payment System (CMS-1809-P). Alliance feedback and recommendations focused on a range of provisions impacting wound care, including:
See the Alliance’s full comments below.
- CTPs/Skin Substitutes: The Alliance once again forwarded recommendations that CMS’s own HOPPS Advisory Panel has endorsed year after year: that CMS update provisions to (1) Enable provider-based departments to be reimbursed for CTP product for larger wounds by paying separately for select add-on codes; (2) Equalize payment for the application of CTPs on wounds/ulcers regardless of anatomic location under a consistent APC code, and (3) Place all new CTPs with "Q" or "A" HCPCS codes in low-cost APCs, unless or until a manufacturer provides CMS with cost data suggesting otherwise. The Alliance's submission to CMS flagged many deficiencies/inaccuracies in the Agency’s “response to comments” that CMS published as rationale for not adopting these previously suggested changes. The Alliance provided correction and clarity on the "response to comments" to further advance CMS consideration of these recommended policy updates.
- Total Contact Casting (TCC): The Alliance requested that CMS again follow the endorsement of its HOPPS Advisory Panel and pay hospital outpatient departments a separate APC for the TCC (APC 5102) when a debridement or graft is performed on the same date of service – something currently denied because of an inaccurate NCCI edit that has been put in place. The Alliance re-forwarded its and the Panel's recommendation that CMS consider HCPCS code 29445 (Application of rigid total contact leg cast) a separately payable code when performed concurrently on the same date of service as select HCPCS codes related to debridement and skin substitute grafts so that facilities can be paid for this separately identifiable service that is not included in the debridement or application of CTPs, and patients can recieve this care.
- Alliance comments also addressed provisions on Blood and Blood Derived Products, Telehealth and Prior Authorization.
See the Alliance’s full comments below.
