Submitted Comments

Items Related to Medicare Administrative Contractors (MACs)

August 7, 2018

Comments to AmeriHealth Caritas Clinical Policy on Full-body Hyperbaric Oxygen Therapy

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.
June 5, 2018

Comments to WPS Wound Care LCD

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
June 22, 2017

Comments to Wisconsin Physician Services (WPS) draft wound care LCD

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
March 9, 2017

Comments to First Coast Service Option draft LCD on wound care (DL37166)

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

Comments to Novitas Solutions draft LCD on wound care (DL35125)

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

Comments to Novitas Solutions draft LCD on treatment of varicose veins of the lower extremities (DL34924)

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 
February 16, 2017

Testimony at FCSO public meeting on draft wound care LCD

The Alliance provided oral testimony at the FCSO public meeting on wound care LCD (DL37166). Testimony focused on: the lack of coverage for disposal negative pressure wound therapy (dNPWT); utilization parameters proposed for NPWT; utilization guidelines that limited debridement; and concerns with policies surrounding the application of Unna Boots or a multi-layer compression system. 
View Alliance Comment
January 26, 2017

Testimony at public meeting on draft Novitas LCD on wound care

The Alliance provided oral testimony at the Novitas Solutions public meeting convened to collect feedback on its wound care LCD (DL35125). Alliance testimony focused on several key issues: the lack of coverage for disposal negative pressure wound therapy (dNPWT); utilization parameters proposed for NPWT that are not based on evidence or clinical practice; utilization guidelines that limited debridement; and concerns with policies surrounding the application of Unna Boots or a multi-layer compression system. 
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 8, 2016

Comments to Cigna Government Services Local Coverage Determination (LCD) for Application of Skin Substitute for Wounds of Lower Extremities (DL36690)

The Alliance submitted comments to Cigna Government Services (CGS) on Local Coverage Determination (LCD) for Application of Skin Substitute for Wounds of Lower Extremities (DL36690). The Alliance reminded CGS that the term “skin substitutes” is clinically inaccurate and should be replaced with more inclusive descriptor “Cellular and/or tissue based products for wounds (CTPs).” The comments addressed issues in the draft policy related to the classification of products, utilization instructions, coverage limitations and confusing language in the guidance regarding its distinction when providing coverage for diabetic foot ulcer (DFU) vs. venous leg ulcer (VLU). Comments also highlighted the need for CGS to recognize podiatrists as providers who can and do treat patients with wounds, and the indications for use (IFUs) for products affected by the LCD. 
View Alliance Comment
August 5, 2016

Comments to Noridian Local Coverage Determination (LCD) for Hyperbaric Oxygen (HBO) Therapy (DL 36686)

The Alliance submitted comments to Noridian on Local Coverage Determination (LCD) for Hyperbaric Oxygen (HBO) Therapy (DL 36686). The Alliance recommended that Noridian revise the policy to recognize the implicit coverage of skin grafts and flaps and expressed concern about the policy’s wording around adjunctive treatment of the diabetic foot ulcer (DFU). Comments also flagged several areas in the draft policy in which Noridian provided specific dose and frequency parameters that are contrary to current standards of practice. In addition, the Alliance noted that some of the evidence that Noridian has used to substantiate the provisions in this policy is outdated. 
View Alliance Comment
February 19, 2016

Comments on the Medicare Administrative Contractors (MAC) contracting process

The Alliance submitted comments to CMS on the Medicare Administrative Contractors (MAC) contracting process. Comments noted that CMS failed to describe what “exceptional MAC performance” means and how that will be measured. The Alliance recommended that CMS be required to provide the metrics on how the contractors are being measured, as transparency would help clinicians and other stakeholders who interact with the Medicare Administrative Contractors (MACs). 
view alliance comment
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