Submitted Comments

Items Related to CMS

September 24, 2018

Comments to CMS CY 2019 Hospital Outpatient Prospective Payment System

The Alliance submitted comments to CMS in response to its proposed CY 2019 Hospital Outpatient Prospective Payment System (PPS) and Ambulatory Surgical Center Payment Systems as well as changes to the Quality Reporting Programs. The Alliance focused its comments on provisions related to:
  • CTP packaging and payment methodology
  • Pass through status for CTPs
  • Guidelines
  • Methods to control unnecessary increases in the volume of outpatient services
  • Ways to control unnecessary costs
  • Price transparency

Read Alliance Comments    Attachment A to comments       Attachment B to comments
September 10, 2018

Comments to CMS CY 2019 Physician Fee Schedule

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
July 22, 2018

Comments to CMS Pre-Claim Review Demonstration Project for Home Health Services

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

Comments on CMS FY2019 Hospital Inpatient Prospective Payment System

 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.
March 2, 2018

Comments to CMS on “Hospital Harm - Hospital-Acquired Condition: Pressure Injury" Measure

 

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
November 20, 2017

Comments to CMS “Request For Information” on the new direction of the Center for Medicaid and Medicare Innovation

The Alliance submitted comments 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. 
View Alliance Comment
September 11, 2017

Comments on the proposed CY 2018 Hospital Outpatient Prospective Payment System

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). 
View Alliance Comment
September 11, 2017

Comment on the proposed CY 2018 Physician Fee Schedule

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
August 21, 2017

Comments to CMS CY Updates to the Quality Payment Program

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
June 13, 2017

Comments to CMS' Hospital Inpatient Prospective Payment System; FY 2018 Rates for Acute Care Hospitals and the Long-Term Care Hospitals

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.
View Alliance Comment
December 19, 2016

Comments on MACRA final rule guiding MIPS and APMs

The Alliance submitted comments to CMS on its rule: Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Comments focused on ensuring that CMS considered of the impacts of the evolving value-based care/payment reform policies to wound care. The Alliance submitted comments to MACRA's quality physician payment proposed rule as well as on the "quality measures development plan," "patient relationships categories and codes," and "episode groups" draft policies.
View Alliance Comment 
September 6, 2016

Comments to CMS regarding the Hospital Outpatient Prospective Payment System

The Alliance submitted comments to CMS on the Hospital Outpatient Prospective Payment System noting that no measures in the Hospital Outpatient Quality Reporting program are specific to wound care. The Alliance reminded CMS that there are 21 quality measures specific to the practice of wound care, fully programmed, as electronic clinical quality measures available within the U.S. Wound Registry Qualified Clinical Data Registry. Furthermore the Alliance expressed concerns on the flawed methodology CMS uses to calculate the payment for cellular and tissue-based products for wounds (CTPs, referred to in the policy as skin substitutes).
View Alliance Comment 
September 6, 2016

Comments on the CY2017 Physician Fee Schedule

The Alliance submitted comments to CMS on its proposed Physician Fee Schedule update: "CMS-1654-P: Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Medicare Advantage Pricing Data Release; Medicare Advantage and Part D Medical Low Ratio Data Release; Medicare Advantage Provider Network Requirements; Expansion of Medicare Diabetes Prevention Program Model." Alliance comments focused on wound care services it viewed as improperly/inaccurately valued by the fee schedule. The Alliance also called for increased transparency on how CMS will use global service data. Additional, the Alliance requested that CMS review its criteria for the expansions of the upcoming Diabetes Prevention Program model as the Medicare Diabetes Prevention Program (MDPP).
View Alliance Comment 
August 29, 2016

Comments on proposed changes to the Medicare Appeals Process

The Alliance submitted comments to CMS’s proposed ruleMedicare Program; Changes to the Medicare Claims and Entitlement, Medicare Advantage Organization Determination, and Medicare Prescription Drug Coverage Determination Appeals Procedures.”  Comments noted the Alliance’s concern that theMACs (Medicare Administrative Contractor) and Qualified Independent Contractors (QIC)are not equipped to appropriately apply precedential decisions,” and raised concerns about many contractors’ inaccurate application of LCD and NCD criteria.The Alliance recommended that CMS create a process to review and reject outdated precedents and suggested that CMS create a process for interested parties to challenge existing precedent. Additionally, the Alliance suggested that all Medicare providers and contractors be trained and educated by CMS on the proper procedures governing precedential cases. The Alliance recommended that CMS provide its contractors with a summary of each case precedent to simplify the process of applying precedent to future appeals.
View Alliance Comments
August 25, 2016

Comments to CY 2017 Home Health Prospective Payment System Rate Update

The Alliance submitted comments to CMS on its proposed policy update “CY 2017 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements.” Alliance commentsfocused on the proposed rule’s implementation of the newly created statutory benefit to pay home health agencies separately for disposable Negative Pressure Wound Therapy (NPWT). The Alliance requested that the Agency clarify the section regarding payment for the time that the home health agency provides the disposable NPWT. The Alliance recommended that in addition to paying for the disposable NPWT devices, CMS also pay the home health agency the nursing time and travel for initial and subsequent visits to those patients requiring home health services who can benefit from the use of disposable NPWT.
View Alliance Comment
August 12, 2016

Comments on CMS Patient Relationship Categories and Codes

The Alliance submitted comments to CMS’s on its draft policy on Patient Relationship Categories and Codes. Comments noted that the proposed rule puts another burden on the clinician for tracking, coding and documentation but adds no value to patient care, or treatment outcomes. The Alliance emphasized to CMS that currently under MIPS, there are no quality measures that a wound care clinician can report for the actual wound care treatment they perform. As such, the obligatory reporting of quality, resource use, and clinical performance measures may not truly be indicative of neither the wound care work wound care practitioners do nor of the resources that they use to treat their patients. Thus, resource use for any wound care clinician will be skewed until this issue is resolved. The Alliance suggested that the Patient Relationship Categories and Codes rule be delayed at least unto 2018 or beyond to allow clinicians sufficient time to adjust to all the other MACRA and MIPS documentation and reporting changes and challenges.
View Alliance Comment
August 3, 2016

Comments to AHRQ regarding Treatment Strategies for Patients with Lower Extremity Chronic Venous Disease

As member of the Venous Care Partnership, the Alliance submitted comments to the Agency for HealthCare Research and Quality (AHRQ) on the June 28, 2016 Technology Assessment (TA), “Treatment Strategies for Patients with Lower Extremity Chronic Venous Disease (LECVD).” The comments expressed concern about that the assessment relied solely on research published after the year 2000, as the diagnosis and treatment of venous diseases has a long history and much of the evidence supporting the diagnosis and treatment of venous disease was established before the limited time period covered by this review. 
View Alliance Comment
May 9, 2016

Comments to CMS on Medicare Program; Part B Drug Payment Model

The Alliance submitted comments to CMS on the Medicare Program; Part B Drug Payment Model stating that it “disagrees with a broad sweeping change to the payment methodology for drugs and biologics…since there is no evidence to support the change.” The Alliance noted that it believes that the proposed rule focuses solely on costs rather than on the complexities of patient care. The Alliance urged CMS to go through a formal rulemaking process for Phase 2 instead of a sub-regulatory process – which is insufficient due to the complexity of the models being developed. 
View Alliance Comment
March 1, 2016

Comments on MACRA Episode Groups

The Alliance submitted comments to CMS on MACRA Episode Groups. In its comments, the Alliance reported that chronic wounds and ulcers are reaching epidemic proportions in the United States. Despite their prevalence, this problem remains off the CMS radar screen even though Medicare will devote at least $30 billion dollars to their treatment this year (and by some estimates, twice that amount). The Alliance urged CMS to create episodes of care around the following high resource use conditions:
  • Diabetic foot ulcers
  • Venous stasis ulcers
  • Stage 3 and 4 pressure ulcers
View alliance comment
March 1, 2016

Comments to CMS on CMS Quality Measure Development Plan

The Alliance submitted comments to CMS on its Quality Measure Development Plan. The Alliance emphasized chronic wound care’s significant economic burden to Medicare and other health care payers. The Alliance encouraged CMS to also adopt measures used in Qualified Clinical Data Registries (QCDR) while also utilizing those under PQRS.
VIEW ALLiance Comment
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