The Alliance submitted comments to CMS in response to its Request for Information regarding Patients Over Paperwork related to reporting and documentation requirements, coding and documentation requirements for Medicare or Medicaid payments, and prior authorization procedures. Our comments focused on several key issues, including:

• NCCI edits
• HCPCS coding reform
• Local coverage decisions (LCDs) versus coverage articles (LCAs)
• Prior authorization
• Billing for disposable negative pressure wound therapy in home health care setting
• Implementation timing of rules issued by CMS

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