Submitted Comments
November 21, 2017
The Alliance submitted a letter in support of H.R. 2445, the DMEPOS Access and Transparency Act of 2017, also known as the DATA Act of 2017. The Alliance noted concern about the impact that prior authorization for negative pressure wound therapy (NPWT) will have in a clinician’s ability to continue treatment protocols for patients while awaiting a prior authorization approval. The Alliance recommended that prior authorization should only be used when patients are not already undergoing treatment for a condition. Once treatment begins, any prior authorization requirement will impact their care. The Alliance requested that NPWT technology be carved out from the DATA Act’s prior authorization requirements in order to ensure that patients have uninterrupted access to NPWT for severe and chronic wounds and burns when Medicare local coverage criteria are met.
November 20, 2017
The Alliance submitted to CMS’ request for information on new directions for the CMMI after convening many conference calls with members to determine issues of importance. Comments focused on opportunities within specialty physician models, program integrity, and benefit design/price transparency. The Alliance focused on the growing importance of real-world evidence and patient registry data. Comments spoke once again to the importance of developing quality measures that are more relevant to wound care and pointed again to the relevance of HCPCS coding reform to the CMMI’s focus on improved payment models – given the correlation of coding and payment in practice. Finally, the Alliance highlighted other models for CMMI consideration, including patient accountability models and Voluntary Quality Improvement Reporting Model for Hyperbaric Oxygen Therapy and population management models.
October 11, 2017
The DMEMACS sent the Alliance a “clarification letter” in October 2017, responding to our September letter requesting clarity on issues that the Alliance had raised with regard to collagen dressings, staging systems and hydrogels - areas of the LCD that would cause confusion in clinical practice and impact patient care/patient access to products and services.
September 11, 2017
The Alliance submitted comments to CMS addressing the proposed CY2018 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and quality reporting programs. Comments focused on issues with the methodology for packaging of skin substitutes (Cellular and/or Tissue Based Product for Skin Wounds, or CTPs). In response to CMS’s request for information on flexibility and efficiency opportunities to increase care, reduce costs and reduce burdens for clinicians and patients, the Alliance asked the agency to consider reform of the process it uses to assign new Healthcare Common Procedure Coding System (HCPCS) Level II billing codes to durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS).
September 11, 2017
The Alliance submitted comments to CMS on the proposed CY2017 Physician Fee Schedule. Comment focused on:
The under estimation and erroneous valuation of 2 CPT codes: CPT 29580 (Strapping of Unna Boot), and CPT 29581 (Application of multi-layer compression system).
Supporting the decision to update the equipment items and the amount of oxygen for hyperbaric oxygen therapy (HBOT) so that the amount of oxygen conforms to the RUC recommended value.
Requesting national payment rate for CPT Codes 97607 and 97608 - describing negative pressure wound therapy (NPWT) services using a disposable device - similar to the rate proposed in the CY2018 hospital outpatient proposed rule.
In response to CMS’s request for information on flexibility and efficiency opportunities to increase care, reduce costs and reduce burdens for clinicians and patients, the Alliance asked the agency to consider reform of the process it uses to assign new Healthcare Common Procedure Coding System (HCPCS) Level II billing codes to durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS).
September 11, 2017
The Alliance submitted a letter to the DMEMAC Medical Directors regarding the application of New Provisions of Surgical Dressing LCD (L33831). The letter reported to the DMEMACs that there was significant disagreement and confusion over how certain LCD provisions should be applied. The Alliance requested clarification on the coverage criteria for collagen dressings and for clarity on confusing wound staging criteria and pressure injury terminology included in the policy.
August 21, 2017
The Alliance submitted comments to CMS addressing the agency’s proposed updates to the Quality Payment Program (CMS-5522-P). Comments focused on the lack of relevant quality measures addressing the needs of wound care clinicians. The Alliance suggested that the creation of additional wound care quality measures is necessary to ensure continued quality care. Comments supported the use of QCDRs and the ability of all eligible clinicians to use the QCDR option for reporting.
July 14, 2017
The Alliance submitted comments to the DMEMAC medical directors requesting that the future Surgical Dressing LCD (L33831) be withdrawn. The Alliance outlined ways in which the LCD undermined clinical judgment and imposed unnecessarily strict frequency limitations on all dressings. The Alliance noted in its comments that the LCD and accompanying policy article do not conform to current clinical practice, lack clarity and contain conflicting language leading to confusion in wound care practice of the clinical community.
June 22, 2017
The Alliance submitted comments to Wisconsin Physician Services’ (WPS) draft wound care LCD (DL37228). Comments focused on utilization parameters for debridement, utilization parameters for negative pressure wound therapy (NPWT) and other areas. The Alliance noted that the policy lacks a foundation in medical evidence or clinical practice. The Alliance also pointed to inaccuracies and confusing/conflicting language in the LCD.
June 13, 2017
The Alliance submitted comments to CMS’ Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Fiscal Year 2018 Rates (CMS-1677-P). Comments advocated for the removal of ulcer measure NQF #0678, replacing it with a modified version of the measure entitled, “Changes in Skin Integrity Post Acute Care: Pressure Ulcer: Injury.” Comments also expressed the need for clarification on terminology used throughout the regulation related to pressure ulcers and injuries. The Alliance supported the proposed adoption of four malnutrition eCQMs measures.
