Submitted Comments

Items Related to Prospective Payment System (PPS)

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
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.
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
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
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 
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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