Submitted Comments

Items Related to Negative Pressure Wound Therapy (NPWT)

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
November 21, 2017

Letter to Rep. Marsha Blackburn (R-TN) requesting exclusion of NPWT from prior authorization as part of HR 2445

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
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
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
May 1, 2017

Testimony at Wisconsin Physician Services (WPS) public meeting convened to collect comments on draft wound care LCD

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

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 
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 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
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