Submitted Comments

October 13, 2020
The Alliance met (virtually) with USP leadership then submitted a follow-up letter advocating the need for a wound care subcategory in United States Pharmacopeia's (USP) Medicare Model Guidelines. Establishment of this subcategory would help to distinguish the chronic wound products from other subcategories - which in turn would better protect coverage of wound care products under Medicare Part D.
See Alliance Letter
SEE ACCOMPANYING PRESENTATION
October 2, 2020

The Alliance submitted comments to CMS’s proposed CY2021 Hospital Outpatient Prospective Payment System. Our comments:

  • Encouraged use of the “Cellular and/or Tissue Based Products for Wounds “(CTPs)  terminology in policymaking, in place the currently used “skin substitutes.”
  • Supported inclusion of Synthetic CTPs in the definition of “skin substitutes” but expressed significant concerns with the Agency’s proposed establishment of the code C1849 (“Skin substitute, synthetic, resorbable skin substitute per square centimeter) to define an entire class of non- branded products and its placement in the OPPS high cost payment package. The Alliance reviewed the impacts of this code as proposed and submitted a number of alternative recommendations.  
  • Requested that Hyperbaric Oxygen Therapy be added to the list of services that require direct supervision
  • Sought clarification on how provider based departments should make decisions on the level of service assigned to code G0463 (hospital outpatient clinic visit) once the new 2021 E/M guidelines are in place.
READ ALLIANCE COMMENTS
October 2, 2020

The Alliance submitted comments and recommendations to CMS’s proposed CY2021 Physician Fee Schedule. Our comments:

  • Oppose cuts in  payment for surgical procedures and physical therapy services and urged the Agency to prevent drastic cuts from occurring while physicians are still trying to recover and gain their financial footing from the effects of the pandemic.
  • Urge CMS to not only accept the RUC recommendations for the values of E/M codes, as they have proposed, but to also apply these updated values to the global procedure codes. We flagged that implementing new values for E/M codes when billed independently - but not implementing those same values in the global packages - disrupts the relativity in the entire physician fee schedule and creates specialty differentials even when performing the same work.
  • Recommend that the Agency consider creating a MIPS Value Pathway (MVPs) for Chronic Wound Management and utilize the QCDR measures which already exist for wound care. 
  • Encourage CMS to maintain a patient’s home as an originating site even when the Public Health Emergency expires. 

Read Alliance comments

 

August 14, 2020
The Alliance provided written and oral comments to CMS' August 2020 CMS Advisory Panel on Hospital Outpatient Payment. Comments focused on provisions related to "synthetic skin substitutes" and included recommendations to:
  • Eliminate the new code C1849 – synthetic skin substitutes resorbable and require any synthetic skin substitute to apply for an appropriate HCPCS Q code to be considered a “skin substitute.”
  • Remove placement of the C1849 synthetic skin substitute products from the high cost tier.
  • Change the current “skin substitute” terminology to “cellular and or tissue based products for skin wounds."
Read Alliance comments
August 11, 2020
The Alliance co-signed a letter to the Senate Finance Committee expressing concern regarding legislation (S. 4295) that would allow Health and Human Services to extend the period of Medicare pass-through status in the hospital outpatient setting to any product with that status during the COVID public health emergency. As written, the proposed legislation would allow products that have already had well over the statutory period of two-to-three years to have extended pass-through time – in some cases, more than double the statutory limit. The letter focused on the impact such a pass-through extension would have on CTPs and noted the importance of ensuring access to all CTP products in the market to support clinical choice and patient value. “Extending the pass-through term of CTP products well beyond the normal pass-through period drastically detracts from that effort. We believe this skews patient access as it incentivizes use of these CTP pass- through products over others in an otherwise established market,” the letter stated.
Read Co-Signed Letter
July 3, 2020
The Alliance submitted comments to CMS's COVID-19 Public Health Emergency Second Interim Final Rule that provided additional policy and regulatory revisions to provide flexibility during the pandemic. The Alliance  providing specific comments and recommendations addressing:
  • The codes that should be utilized by Provider Based Departments (PBD) when billing for wound care services via telehealth that has been temporarily relocated to a patient’s home
  • Competitive bidding program concerns
  • Temporary relocation sites
  • The Appropriate Use Criteria (AUC) program
  • Merit-based Incentive Payment System (MIPS) Program Relief
  • LCD/DME issues

Read Alliance press release
See Alliance Comment
June 4, 2020
The Alliance submitted a letter to three Medicare Administrative Contractors (MACs) addressing payment policies for services provided in the home (POS 12), assisted living facilities (POS 13), and nursing facilities (POS 32). In comment to Palmetto, National Government Services (NGS) and Wisconsin Physician Services (WPS), the Alliance suggested that for practitioners providing wound care  in these sites, application of cellular and/or tissue products for skin wounds (CTPs) and disposable negative pressure wound therapy services be paid at the applicable Medicare physician non-facility rate. "We submit that Policy Manual provisions along with the waivers that have been issued support our request…We are concerned that [MACs] have not been covering these services in these settings, even though there is a dire need to provide care to these patients.  Enabling payment of these proven wound care therapies (already covered by Medicare) would allow access to care while reducing the risk of COVID transmission for vulnerable wound care beneficiaries," the Alliance wrote. 
Letter to Palmetto
Letter to NGS
Letter to WPS
May 29, 2020
The Alliance has continued our proactive wound care advocacy with CMS surrounding the waivers and flexibilities implemented in policies addressing medical care amid the COVID-19 crisis. In comments to CMS's Interim Final Rule, the Alliance supported the Agency’s implementation of many policies while also pursuing clarification on several specific provisions that we'd flagged in our April 6th letter to the Agency that still have not been addressed. These included advocacy on issues related to surgical dressing benefits, negative pressure wound therapy billing, CTP co-pays, reimbursement and increased access for alternative methods of debridement, documentation requirements,  and more. The Alliance provided specific policy recommendations and requested that CMS add to its series of upcoming "Office Hours" teleconferences a call specific to wound care as well as one for DME suppliers/providers and manufacturers of medical equipment.
Read Alliance comments
April 6, 2020
In response to the COVID-19 crisis, the Alliance has continued our proactive wound care advocacy by sending our letter to Secretary Alex Azar, Administrator Seema Verma and their staff requesting temporary regulatory waivers to give flexibility to wound care clinicians to provide necessary procedures and products to treat their patients amid the evolving realities of the pandemic. The  Alliance identified specific regulatory provisions related to site of service, reimbursement, documentation, DME access and other issues that, with regulatory relief, could remove barriers to treat wound care patients efficiently and effectively during this pandemic while at the same time keeping them as safe as possible while they receive the necessary care.
READ ALLIANCE LETTER
March 31, 2020

The Alliance submitted recommendations  regarding payment methodologies for cellular and/or tissue based products for skin wounds (CTPs) for the Agency to consider prior issuing proposed rulemaking for Calendar Year 2021. The Alliance highlighted that there are many differing interpretations of the three payment methodologies that CMS has been considering: Episodic Payment, Single APC, and Comprehensive APC. The Alliance outlined its  understanding of each methodology, and sought to clarify if its definitions and interpretations were correct. "Once we come to an understanding of the definitions, we can better offer our specific recommendation," the Alliance informed CMS. 
READ ALLIANCE LETTER

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