Submitted Comments

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). 
View Alliance Comment
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.
View Alliance Comment
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.
View Alliance Comment
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submitted comments to the DMEMAC medical directors requesting that the future Surgical Dressing LCD (L33831) be withdrawn.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. 
View Alliace Comment
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. 
View Alliance Comment
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.
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May 1, 2017
The Alliance provided oral testimony at the Wisconsin Physician Services (WPS) public meeting on its draft wound care LCD (DL37228). The Alliance voiced concern that WPS has created arbitrary parameters without clinical or scientific basis. In its submitted comments, the Alliance requested that WPS provide the evidence for the utilization parameters identified with respect to debridement as well as Negative Pressure Wound Therapy (NPWT).
View Alliance Comment
March 9, 2017
The Alliance submitted comments to FCSO’s wound care draft LCD (DL37166). Comments noted that the LCD lacked a foundation in medical evidence and clinical practice guidelines in regards to utilization parameters for both debridement and NPWT. Furthermore, the Alliance noted that the LCD lacks sufficient evidence for the change in coverage for disposable negative pressure (dNPWT) products.  The Alliance expressed concerned that FCSO may be using problematic proprietary claims data as a rationale in crafting this policy. The comments also pointed to inaccurate information and confusing/conflicting language found throughout the policy.
View Alliance Comment
March 9, 2017
The Alliance submitted comments to Novitas Solutions on wound care draft LCD (DL35125). Comments noted that the LCD lacks compelling medical evidence and clinical practice guidelines support for the utilization parameters proposed for debridement and negative pressure wound therapy (NPWT). The Alliance also expressed concern about the changes in coverage for disposable NPWT (dNPWT). The comments point out that FCSO may be relying on problematic proprietary claims data as a main source in crafting the draft regulation. The comments also note inaccurate information and confusing/conflicting language found throughout the policy.
View Alliance Comment 
March 9, 2017
The Alliance submitted comments to Novitas Solutions on draft LCD (DL34924) regarding the treatment of varicose veins of the lower extremities. Alliance comments support those submitted by the American College of Phlebology and the American Venous Forum and Society of Vascular Surgeons.  Each of these groups expressed concern that the proposed regulation arbitrarily limits access to care for patients with clinically significant disease and selectively applies certain clinical practice guidelines while ignoring others. The Alliance expressed concerns that the draft LCD goes against prior LCDs from other Medicare administrative contractors (MACs) as well as most commercial carriers.
View Alliance Comment 
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