Submitted Comments

September 10, 2018
The Alliance submitted comments to CMS' proposed CY 2019 Physician Fee Schedule supporting specific provisions to ease paperwork/documentation burdens, including:
  • Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit; 
  • Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient; 
  • Allowing physicians to choose between current documentation guidelines, documenting by time only, or documenting by medical decision making only; 
  • Removing the need to justify providing a home visit instead of an office visit. 
However,  the Alliance also used its comments to voice its strong opposition to the consolidation of Evaluation and Management codes and the corresponding reduction in payment for E/M services for those that provide the most complex care. The Alliance submitted a series of examples of unintended consequences that the proposal would create and urged CMS not to move forward with that provision. 
Read Alliance Comment
August 7, 2018
The Alliance submitted comments addressing the AmeriHealth Caritas Clinical Policy on Full-body Hyperbaric Oxygen Therapy (HBO2). While supportive of the need for safe and effective HBO2 and the need for policies that minimize administrative burdens while still being easy to implement and enforce, the Alliance identified clinically inaccurate and/or unsubstantiated information within the policy to be addressed as the policy is revised.

Read the Alliance comment.
August 3, 2018
The Alliance submitted a letter to Congress supporting the Lymphedema Treatment Act (S. 498, H.R. 930). The Alliance recommended that Congress grant CMS the statutory authority to cover compression bandages and garments for lymphedema under the Medicare benefit, noting that this change could have a substantial impact via improved outcomes and quality of life, reduced costs for beneficiaries and the health care system, and decreased federal spending. 

Read Alliance comment.
July 22, 2018
The Alliance submitted comments to CMS in response to its request for comments on “Pre-Claim Review Demonstration for Home Health Services.” While the Alliance understands that the rationale for bringing this failed demonstration project back is to address issues of fraud and abuse, we noted in comments that the policy would create a significant administrative burden on home health agencies. Most concerningly, it would have a tremendous negative impact on the access to care for beneficiaries in order for CMS to target a few “bad apples.”

Read Alliance comment. 
June 24, 2018
 The Alliance submitted comments that overall supported CMS’ efforts to streamline and de-duplicate measures. However, in comments to “Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Fiscal Year 2019 Rates,” the Alliance noted concerns with some of the provisions directly impacting wound care and, specifically, pressure ulcers. The Alliance recommended that CMS:
  • Remove pressure ulcers (PSI 03) from the NQF #5031 Patient Safety and Adverse Events Composite Measure
  • Create a stand-alone quality measure for PSI 03, Pressure Ulcer Rates
  • Or, as an alternative, increase the weight currently outlined in the proposed rule for pressure ulcers.
  • Implement the Equal Measure Weights approach outlined in the proposed rule.
June 5, 2018
Alliance submitted comments to WPS on its proposed Wound Care LCD that went into effect on April 16, 2018. The Alliance noted specific, significant concerns with some of the language contained in the final LCD – including clinically incorrect statements – on requested clarity on several key areas, including:
  •  debridement coverage for chronic non pressure ulcers
  •  debridement coverage for diabetic ulcers
  • utilization parameters for traditional and disposable Negative Pressure Wound Therapy (NPWT)

View Alliance comment
March 2, 2018

 

The Alliance expressed its concern about CMS’ Hospital Harm- Hospital-Acquired Condition -Pressure Injury measure. While the Alliance supports and encourages the continued development of quality measures that assess wound care outcomes, the Alliance flagged that the intended objective will not be achieved the way this measure has been crafted. Overall, the specific language as well as the numerator and denominator, contained within this document are not accurate, wrote the Alliance in its comments. Furthermore, there are scientifically incorrect statements within this proposed measure.  “It is very concerning that CMS has tied a Pressure Injury Measure to Hospital Harm. As stated throughout our comments – it is possible for a patient to develop or have a pressure ulcer without any harm. If this measure continues as a quality indicator to measure harm, there will be unintended consequences - either an increase in the number of lawsuits, or an increased likelihood that hospitals will be unable to defend themselves against frivolous litigation - despite the best care being provided.”
View Alliance comment
January 4, 2018
The DMEMACs responded to the Alliance’s December 2017 letter flagging inconsistencies between the guidance the DMEMACs provided to the Alliance in an October 2017 “clarification letter” and the instructions that Noridian gave in a November educational webinar on the surgical dressing LCD.
View Alliance Comment
December 18, 2017
The Alliance alerted the DMEMACs that the information being given out on the Nov. 30, 2017 Noridian surgical dressing educational webinar about the new surgical dressing LCD differed from the information provided to the Alliance in the Oct. 20, 2017 “clarification letter.” The DMEMAC medical directors had developed the clarification letter for the Alliance in response to its detailed questions. The Alliance suggested that a more formal DMEMAC Advisory would be appropriate so that other stakeholders could benefit from the clarity provided to the Alliance regarding the surgical dressing policy.
View Alliance Comment 
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. 
View Alliance Comment
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