Advocacy Accomplishments
The Alliance's impact in 2023 was extensive.
as a result of our tenacious advocacy, we:
- Successfully achieved withdrawal of highly problematic CTP local coverage policies for the treatment of diabetic foot ulcers & venous leg ulcers.
- Following a multi-prong Alliance-led advocacy initiative and grassroots mobilization across the wound care community, on Sept. 28th, CGS Administrators, First Coast Service Options, and Novitas announced that their “Skin Substitute Grafts / Cellular and/or Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers” local coverage determination and articles (LCDs/LCAs) were being withdrawn for further vetting. If these policies had gone into effect on Oct. 1 as scheduled, they would have disrupted care and dramatically restricted access to CTPs (skin substitutes). Looking ahead: work with policymakers will continue into 2024 as potential new policies are shaped.
- Successfully mobilized CMS to make technical correction to HBOT payment rate.
- When CMS implemented a 40% reduction to the payment rate for Hyperbaric Oxygen Therapy (HBOT) that would have resulted in site closures and limited patient access, the Alliance’s collaborative advocacy with hyperbaric oxygen stakeholders across the country resulted in CMS correcting and re-issuing the HBOT payment rate in an update to the 2024 Hospital Outpatient Prospective Payment System.
- Gained endorsement of CMS’ Advisory Panel on Hospital Outpatient Payment to correct flaws in CTP payment methodology.
- Presented to the Panel five recommendations to remove barriers to patient access to CTPs. Each was endorsed (again, for the third year in a row), included in the Panel’s September 2023 report to CMS, and submitted directly to CMS via the Alliance comments. Looking ahead: as these recommendations were again not incorporated into CMS’ final rule, Alliance advocacy continues.
- Elevated surgical dressings claims processing process issues and denials that have created a lack of patient access.
- Submitted a letter to the DMEMAC medical directors flagging denials for alginate or other fiber gelling dressings, surgical dressing modifier quantity limitations, and a lack of alignment in the claims processing system with the HCPCS codes and modifiers when a category of dressing is used for multiple wounds. Provided recommendations on process and policy changes and scheduled a January 2024 meeting with the DMEMACs. Update: in March 2024, the DMEMACs published an update of their surgical dressing policy article that implemented Alliance-recommended policy changes.
Expanded awareness of the burden, prevalence & cost of chronic wounds
- Following up on our 2018 economic impact study, the Alliance co-authored a new economic impact study published in the Journal of Medical Economics (July 2023) demonstrating the changing landscape of chronic wound care and costs, and providing greater transparency on how Medicare coverage and payment policies are influencing where wound patients are receiving care. The study brought to light important shifts in site-specific spending and costs: Findings showed the number of Medicare beneficiaries with chronic wounds increased from 8.2 million (14.5% of Medicare patients) to 10.5 million (16.4% of Medicare patients) from 2014–2019, amid a 20% reduction in chronic wound expenditures. Importantly, the study confirmed the shift from patients being treated in HOPD to the physician’s office: HOPD fees saw the largest reduction ($10.5 billion to $2.5 billion) while physician offices saw an increase from $3 billion to $4.1 billion.
shaped policy development as we:
Encouraged Medicare payment reform and mitigation of physician payment cuts:
- Urged Congress to take steps on “transformative” Medicare payment reforms to protect the clinician workforce in a letter co-signed with 100+ medical professional organizations representing more than one million healthcare providers.Voiced opposition to the Clinical Labor Update and its significant cuts in reimbursement that undermine the long-term financial viability of physician practices. Supported the “Providing Relief and Stability for Medicare Patients Act of 2023” that would mitigate cuts to office-based specialists for a targeted group of services, helping to avoid significant disruptions in patient access to care. Opposed reimbursement cuts in the Medicare Physician Fee Schedule that would undermine the long-term financial viability of physician practices.
- Sought fair payment for medical providers and allied health professionals in the measuring, fitting, and training services of Lymphedema compression treatment items.
- Convened educational session with key CMS staffers focused on fitting, application and the need for additional CPT procedure codes to account for the time and expertise required. Submitted comments to the proposed 2024 Home Health PPS. Looking ahead: Dialogue with CMS and DMEMAC medical directors remain ongoing.
Tackled a broad range of policy issues that impact patient care:
- In 2023, we’ve addressed coding, coverage, and payment with the submission of 26 comments to regulatory agencies and Congress on policies spanning the Medicare Physician Fee Schedule, Hospital Outpatient Prospective Payment System (PPS), Hospital Inpatient PPS and Home Health PPS. We tackled policy issues related to CTPs, surgical dressings, topical oxygen, blood derived products, negative pressure wound therapy, compression, and more. We provided recommendations on CMS’ prior authorization processes and proposed coverage of emerging technologies pathway. We provided perspective to FDA’s guidance on decentralized clinical trials. We reached out to Congress to support legislation impacting wound care and urged attention to Medicare payment reforms.
Our progress and successes are a testament to the strength, power, and influence of having a unified - and tenacious - voice for wound care advocacy. Learn more in the Alliance's 2023 Annual Report. See how we've been driving change and moving wound care forward for the past 20 years:
For information on accomplishments of previous years, see below:
