Submitted Comments
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As hospitals and health systems are directed to halt all elective and “non essential” services as part of COVID-19 response, a concerning number have categorized wound care services and procedures as “non essential” – leaving a fragile cohort of chronic wound patients at risk. The Alliance developed a position statement to help health systems and providers avoid unintended consequences for wound patients amid the realities of the COVID-19 pandemic: “Wound Care is an Essential, Not Elective, Service that Prevents Hospital Admissions and ED Visits Among a Fragile Cohort of Patients at High-Risk of Mortality from COVID-19.”
See Alliance COVID-19 Resources for Wound Care
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The Alliance submitted comments to the DME MACs' preliminary determination to not cover Topical Oxygen Therapy (TOT) for would healing. The Alliance outlined why the current analysis of evidence on which the LCD was based is "incomplete" and urged the DME MACs to consider the available evidence on a per wound-type basis (i.e., for diabetic food ulcers) and make wound type-specific coverage determinations. See additional Alliance recommendations in the full-text comments, below.
As part of comments submitted to Wisconsin Physicians Service Insurance Corporation’s Draft Local Coverage Determination for Wound Care, the Alliance flagged eight key concerns and flaws within the policy that negatively impact patient care. Comments focused on WPS’ limiting coverage of debridement while not providing adequate scientific evidence to support its coverage policy. The Alliance questioned the policy’s elimination of a significant number of CPT codes related to debridement and the inclusion of only a limited number of conditions which must be present in order to provide a debridement. The Alliance also flagged many areas where the policy conflicted with other existing DMEMAC policies or violated processes in CMS’s Program Integrity Manual. These comments follow similar comments submitted to WPS in 2017, 2018 and early-2019 raising the same issues.
The Alliance submitted comments to the United States Pharmacopeia's (USP) draft Medicare Model Guidelines advocating for creation of a new subcategory for wound care products. Under the current policy, wound care products are in the “Dermatological, Other” category that includes a long list of products for a variety of conditions with varying severity, such as acne and lice treatments. The Alliance requested that the USP add a subcategory titled “wound care” under Dermatology to distinguish the chronic wound products from other subcategories in Dermatology, which would also better protect coverage of wound care products under Medicare Part D.
- The broad sweep to move all therapeutic services from direct to general supervision
- The implementation of prior authorization for procedures that are often utilized to treat chronic wounds that threaten both life and limb
- Payment methodologies for CTPs
- Lump-sum episode based payment for a wound care episode
- The single Ambulatory Payment Classification (APC) proposal and C-APC methodologies
- Inaccurate APC Group assignments for CTPs due to facilities' incorrect coding/billing, which for years has resulted in APC Group assignments that fail to reflect the true costs of the CTPs.
The Alliance submitted detailed comments to CMS on a range of provisions in the proposed Physician Fee Schedule that impact wound care providers. Comments focused on:
- Evaluation and Management Codes
- The conclusions of three RAND Corporation reports utilized in the report to support certain provisions (CMS had contracted RAND to collect data on the number and level of post-operative visits for surgical global codes provided to Medicare beneficiaries)
- Relative Value Units (RVUs) for Physical Therapy
- Practice Expense (PE) RVUs for Disposable Negative Pressure Wound Therapy (CPT Codes 97607 & 97608)
- Open Wound Debridement (CPT Codes 97597 and 97598)
- Ultrasonic Wound Assessment (CPT Code 97610)
See additional comments and recommendations submitted to CMS in the full-text Alliance comments below.
