Alliance of Wound Care Stakeholders

Advocacy Accomplishments

The Alliance of Wound Care Stakeholders serves as the go-to resource to address public policies that may create barriers to wound patients’ access to care. We monitor regulators and payers and respond quickly to changing coding, coverage, and payment policies. And, when decision makers need knowledgeable input about wound-related best practices, they come to the Alliance for guidance. We are the united voice of medical specialty societies and clinical associations, leading wound care organizations and business entities to advocate for appropriate coding, coverage and payment. Our close relationships with government policymakers, payers, regulators, legislators and other decision makers gives us a “seat at the table” as policies are crafted, debated and updated.

As a result of the Alliance’s tenacious 2022 advocacy, we: 


  • Persuaded CMS to delay and re-evaluate the problematic CTP provisions in the 2023 Physicians Fee Schedule Final Rule which included: reclassifying all cellular and tissue-based products for wounds (CTPs, or skin substitutes) as “supplies incident to a physician service,” and packaging payment into practice expenses – a shift that the Alliance believed would create barriers to care that could ultimately lead to increased amputations and infections for patients with chronic non-healing wounds.
        • ADVOCACY WIN FOR WOUND CARE: Following tenacious advocacy with the  Alliance urging CMS to remove or delay these highly problematic CTP provisions, they were NOT included in the final 2023 PFS, allowing the Agency time to  review comments and hold a Town Hall meeting in January 2023 to further hear stakeholder concerns and gain insights into ways for CMS to move forward with a consistent payment approach between different sites of service. CMS will then likely issue for CY 2024 a proposed rule containing more details.

  • Elevated wound care voice to U.S. Congress to help ensure that two wound care legislative policy priorities -- the Better Wound Care at Home Act and the Lymphedema Treatment Act -- were included in H.R. 2617, the Consolidated Appropriations Act 2023 that President Biden signed into law on December 29, 2022.

  • Paved the way for Noridian’s release of stalled claims. Prompted Noridian to publish an article on its website providing clarity regarding amniotic and/or placental derived products and report that “claims that have been pending will be released in the upcoming days for processing.”

  • Attained an endorsement from CMS’ Advisory Panel on Hospital Outpatient Payment for the Alliance’s recommendations to fix flawed/inadequate CTP payment policies by enabling provider-based departments to (1) be reimbursed for an adequate amount of CTP products for larger wounds and (2) to equalize the payment for CTP application for wounds/ulcers of the same size no matter the anatomic location. The Panel supported these recommendations for the 2nd consecutive year and elevated them to CMS for consideration.

  • Actuated changes in the 2022 CMS NCCI Edit Manual as the first step to allow for reimbursement of the application of a total contact cast or compression therapy after a debridement or grafting procedure to be performed and reported for the same patient in the same anatomical region on the same day. The Alliance continues to meet and correspond with the NCCI contractor and CMS senior staff to delete the NCCI edits listed in the CPT Manual and CMS Manual Coding Instructions to mirror and reflect the guidance provided in its recently updated NCCI Policy Manual. 



The Alliance effectively shaped policy development as we:

  • Pursued revision/withdrawal CGS’ proposed LCD/LCA on Skin Substitutes for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers; flagged clinical inaccuracies and lack of supportive evidence.
  • Urged Noridian to fix incorrect and outdated terminology in its Wound and Ulcer Care LCD; submitted detailed chart of small but important changes (errors in HCPCS coding, CPT code descriptors, outdated language) that would not require reconsideration process but  would add accuracy and clarity.
  • Improved key CMS policymakers’ understanding of CTPs via two meetings with CMS staff:  a March session with 5 CMS directors and their staffs across 3 divisions of CMS to discuss how the inconsistent HCPCS code assignments for CTPs and synthetic CTPs has led to problematic issues in both the physician office setting and in hospital outpatient provider-based departments; a June educational seminar with 6 CMS directors/deputy directors and 18 senior staff to learn more about CTPs, including the different types, clinical considerations on their use and regulatory pathways.
  • Led the initiative for ASTM to update the CTP standard guide (F3163-22) and its definitions used by payers for terminology purposes.



fostered mutual understanding and a framework for solutions to the question: “What type and how much evidence do payers need to cover wound care products and procedures?” by convening the Wound Care Evidence Summit™

 

  • Organized a critically needed and unique two-day conference that brought together payers, policymakers, researchers, physician specialty societies, patient and clinical associations, wound clinics and manufacturers. Provided a unique platform for this broad range of stakeholders to discuss and build consensus around issues ranging from development of coverage policies, clinical trial endpoints, the acceptance of real-world data and evidence, the current state of wound care research and how clinical practice guidelines and research findings are being used by stakeholders  going forward to advance wound care.

 

As the go-to collaborative organization in wound care, the Alliance joined forces with aligned stakeholders in 2022 to impact change through the following efforts:

  • Opposed payment cuts in the CY 2022 Physician Fee Schedule proposed rule. In joint letters and communications with the Clinical Labor Coalition, requested the help of Congress to address the steep reductions in Medicare clinical labor payments that began  January 1, 2022, and continued through CY 2025 following CMS’ update of the costs of clinical labor in the calculation of practice expense relative value units – an issue that impacts many wound care providers.
  • Partnered with 100+ clinician groups as part of the Conversion Factor (CF) Coalition in letters urging Congress take legislative action to stop the 4.5% reduction to Medicare payment rates from being implemented on January 1, 2023 under the 2023 Physician Fee Schedule.
  • Served as a key resource to the FDA as it planned its April 2022 Wound Healing Scientific Workshop to shape the agenda and position it  synergistically with the Alliance’s Evidence Summit. 
  • Pressed CMS for greater transparency and uniformity in development and implementation of coverage issues and the use of the Carrier Advisory Committees by meeting twice with CMS senior staff and co-signing a letter with American Podiatric Medical Association (APMA) and 18 additional physician specialty societies.
  • Served on the Wound Care Collaborative Community steering committee.
  • Convened our Government Affairs Workgroup to partner with our member organizations that have dedicated government affairs staff on legislative issues impacting the wound care community. The Alliance loaned its name to several sign-on letters and directly submitted letters to support (or oppose) legislative wound care initiatives.
  • Convened CTP Workgroups throughout year to build consensus and action plans on how to best organize and deploy Alliance advocacy and individual member advocacy to address evolving issues surrounding CTPs. 

 

For information on accomplishments of previous years, see below:
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