The Alliance submitted comments to CMS' proposed CY 2025 Home Health Prospective Payment System Update (CMS-1803-P) with a focus on provisions impacting wound care, including:

• Implementation issues surrounding the Lymphedema Treatment Act: The Alliance again flagged its ongoing concern that no coding and payment provisions have been put in place in  Home Health PPS provisions enacting the Lymphedema Treatment Act to ensure that qualified health professionals (“QHPs”) can get reimbursed for the measuring, fitting, and training services they provide when furnishing patients with lymphedema compression treatment item. "We request that CMS ensure payment is provided to the individuals that render these critical services, and to provide patients with meaningful options in seeking measuring and fitting services from the QHP of their choosing....Suppliers are being compensated for all of these despite not performing any of the services. This was not the intent of Congress and is impacting patient access and patient care. Compensating DME suppliers, but not QHPs, for work that QHPs are performing is an inefficient and inequitable use of Medicare dollars, disincentivizes the use of lymphedema clinician/therapists’ expertise in garment selection and diminishes patient choice in the provision of their care," the Alliance wrote. 

Alliance comments also addressed:

• Home health payment rate reductions
• Conditions of Participation (CoPs) standard
• Quality reporting: social determinants of health
• Disposable negative pressure wound therapy
• Initial and comprehensive assessments by physical therapists

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