The Alliance celebrated our 15th anniversary in 2017. Fittingly, we celebrated with a toast, a video, and a year spent productively providing a unified, balanced and clinically sound wound care perspective to CMS, its contractors, FDA, Capitol Hill and other key policy stakeholders in the wound care space. We identified and took advantage of multiple opportunities for input, advocacy and comment. We worked tirelessly to ensure that regulatory agencies were aware of the issues and impacts to wound care as policies were crafted and considered. Our comments put us “on the record,” built credibility and opened doors for ongoing advocacy and dialogue. 2017 demonstrated that having a strong, united voice in today’s hyper-partisan world remains essential. Key accomplishments include:

demonstrated the clinical & economic impact of chronic wounds to Medicare. 

Sponsored first comprehensive wound care study evaluating economic impact and policy impacts of chronic wounds to the Medicare program: “An Economic Evaluation of the Impact, Cost and Medicare Policy Implications of Chronic Nonhealing Wounds.”  The study findings, published online in the economic journal Value in Health (October), illuminated the need for more wound-relevant quality measures, payment models and Federal research funding. Topline findings showed that chronic wounds impact nearly 15% of Medicare beneficiaries (8.2 million) at an annual cost to Medicare conservatively estimated at $28.1 to $31.7 billion. The Alliance ciculated a news release and fact sheet to members and media to gain visibility for the study and its insights. 

Went on the record with comments, oral testimony and letters 17 times in 2017

Pursued accurate, clinically sound local coverage determinations and payment policies via persistent advocacy with A/B MACs, DMEMACs and CMS. In 2017, this included:
  • 6 comments to CMS
  • 7 comments to A/B MACs addressing concerns with wound care LCDs 
  • 2 letters to the DMEMACs raising concerns with the final surgical dressing LCD
  • 1 letter to heads of HHS &  CMS co-signed with the Alliance for HCPCS II Coding Reform
  • 1 letter to Congress regarding the DMEPOS Access and Transparency Act of 2017

minimized the impact of a restrictive draft LCD on NPWT

The Alliance actively responded to a concerning Novitas wound care local coverage determination (LCD) issued in January. We testified at Novitas’ public meeting and submitted comments recording concern about the lack of evidence to support the proposed changes, the elimination of coverage of disposable Negative Pressure Wound Therapy (dNPWT), and the arbitrary utilization parameters set for NPWT and debridement services. The final policy, published in Sept., resolved many of our comments and ultimately included coverage for dNPWT plus more flexibility in performing NPWT.

Secured meaningful clarifications  on DMEMAC surgical dressing LCD

Continued our ongoing, proactive advocacy to address clinical concerns with the DMEMAC final surgical dressing LCD, ultimately driving a “clarification letter” addressing several key issues. The final policy (published in June) was not consistent with how surgical dressing products are prescribed and utilized by wound care clinicians. We collaborated with the Coalition of Wound Care Manufacturers to coordinate a synergistic advocacy strategy. Our advocacy did achieve action and DMEMAC response in the form of a "clarification letter" that addressed several of the key areas of the LCD that were causing confusion in clinical practice and impacting patient care/patient access to products and services. 

Elevated the need for HCPCS coding reform

Elevated the need for HCPCS coding reform to ultimately help improve patient access to medically necessary products and simplify the process for manufacturers to bring products to the wound marketplace. In collaboration with the Alliance for HCPCS II Coding Reform, the Alliance of Wound Care Stakeholders co-signed a letter to (then) HHS Secretary Tom Price and CMS Administrator Seema Verma expressing concerns with the current coding process providing specific reform recommendations. Senior HHS/CMS staff followed-up the letter by meeting twice with Alliance for HCPCS II Coding Reform members (led by Marcia Nusgart) – in Nov. and Dec. – to begin to resolve many of the concerns raised. Additionally, at the November MEDPAC meeting, the Alliance raised the issue in public comments, which led to a January 2018 meeting with MEDPAC staff to address this issue.

For more detailed information on 2017 activities and accomplishments, as well as information from previous years, see below:

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Email: marcia@woundcarestakeholders.org
Phone: 301.530.7846
Fax: 301.530.7946
5225 Pooks Hill Road
Suite 627 South
Bethesda, Maryland 20814
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