Submitted Comments by Year

List of articles in category Submitted Comments
Created Date	Title
2021
June 29, 2021	Letter to the National Correct Coding Initiative (NCCI) contractor : Read More
June 15, 2021	Comments to CY2022 Hospital Inpatient Prospective Payment System (IPPS) : Read More
April 16, 2021	Comments to MCIT Interim Final Rule : Read More
April 13, 2021	Letter to National Quality Forum
March 23, 2021	Letter to CMS Addressing CTP Payment Methodology : Read More
March 15, 2021	Comments to Noridian Draft Wound Care LCD & LCA : Read More
January 20, 2021	Comments to NCD for Autologous Blood-Derived Products for Chronic Non-Healing Wounds : Read More
January 19, 2021	Comments to National Quality Forum's Measure Applications Partnership (MAP) Coordinating Committee : Read More
January 4, 2021	Comments on DMEPOS and HCPCS Coding Process Proposed Rule : Read More
2020
December 22, 2020	Comments to "Securing Updated and Necessary Statutory Evaluations Timely” (SUNSET) Proposed Rule : Read More
November 2, 2020	Comments to CMS proposed rule regarding Medicare Coverage of Innovative Technology (MCIT) and the new definition of “reasonable and necessary” : Read More
October 13, 2020	Letter to USP Urging Wound Care Subcategory in Medicare Model Guidelines : Read More
October 2, 2020	Comments to CMS Proposed CY2021 Hospital Outpatient Prospective Payment System : Read More
October 2, 2020	Comments to Proposed CY2021 Physician Fee Schedule : Read More
August 14, 2020	Comments to CMS Advisory Panel on Hospital Outpatient Payment : Read More
August 11, 2020	Co-Signed Letter to the Senate Finance Committee : Read More
July 10, 2020	Letter to Congress on "Cures 2.0" updates & HCPCS Coding Reform : Read More
July 3, 2020	Comments to CMS COVID-19 Public Health Emergency Second Interim Final Rule : Read More
June 4, 2020	Letter to MACs addressing payment policies for home care, assisted living and nursing homes : Read More
May 29, 2020	Comments to CMS COVID-19 Public Health Emergency Interim Final Rule : Read More
April 6, 2020	Letter to CMS Requesting Temporary Regulatory Waivers : Read More
March 31, 2020	Letter to CMS regarding CTP Payment Methodology Definitions : Read More
March 20, 2020	Alliance Position Statement: Avoid Unintended Consequences for Wound Patients Amid COVID-19 Pandemic Response : Read More
February 10, 2020	Alliance Comments to Draft LCD on Topical Oxygen Therapy for Wound Healing : Read More
February 3, 2020	Comments to Texas Medicaid Draft Policy on Wound Care Management Services : Read More
2019
December 17, 2019	Letter to Congress on "Cures 2.0" updates to 21st Century Cures Act : Read More
November 10, 2019	Comments to WPS Draft LCD for Wound Care : Read More
October 14, 2019	Comments to USP Medicare Model Guidelines : Read More
September 27, 2019	Comments to CY2020 Hospital Outpatient Prospective Payment System : Read More
September 27, 2019	Comments to CY2020 Physician Fee Schedule : Read More
September 9, 2019	Comments to CMS CY2020 Home Health Prospective Payment System : Read More
August 12, 2019	Comments to CMS Patients Over Paperwork : Read More
July 23, 2019	Comments to AHRQ Draft Technical Brief on “Skin Substitutes for Treating Chronic Wounds” : Read More
July 21, 2019	Comments to AHRQ RFI on "The Impact & Use of Evidence-Based Practice Center Evidence Reviews" : Read More
March 11, 2019	Comments to the Physician-Focused Payment Model Technical Advisory Committee (PTAC) : Read More
March 8, 2019	Comments to AHRQ Technology Assessment on Skin Substitutes for Treating Chronic Wounds : Read More
February 17, 2019	Letter to Noridian Requesting Withdrawal of Local Coverage Articles on Medicare Coverage of "Amniotic Membrane-Derived Skin Substitutes” : Read More
2018
December 14, 2018	Comments to Noridian coverage article “Use of Amniotic Membrane Derived Skin Substitutes” : Read More
October 4, 2018	Comments to WPS Wound Care Coding Companion for Wound Care L37228 : Read More
September 24, 2018	Comments to CMS CY 2019 Hospital Outpatient Prospective Payment System : Read More
September 21, 2018	Comments to United Healthcare "Skin and Soft Tissue Substitutes" Policy : Read More
September 10, 2018	Comments to CMS CY 2019 Physician Fee Schedule : Read More
August 7, 2018	Comments to AmeriHealth Caritas Clinical Policy on Full-body Hyperbaric Oxygen Therapy : Read More
August 3, 2018	Letter to Congress Supporting the Lymphedema Treatment Act : Read More
July 22, 2018	Comments to CMS Pre-Claim Review Demonstration Project for Home Health Services : Read More
June 24, 2018	Comments on CMS FY2019 Hospital Inpatient Prospective Payment System : Read More
June 5, 2018	Comments to WPS Wound Care LCD : Read More
March 2, 2018	Comments to CMS on “Hospital Harm - Hospital-Acquired Condition: Pressure Injury" Measure : Read More
January 4, 2018	DMEMAC response to Alliance request for an advisory article addressing surgical dressing webinar : Read More
2017
December 18, 2017	Letter to DMEMACs requesting clarification of misinformation shared on surgical dressing educational webinar : Read More
November 21, 2017	Letter to Rep. Marsha Blackburn (R-TN) requesting exclusion of NPWT from prior authorization as part of HR 2445 : Read More
November 20, 2017	Comments to CMS “Request For Information” on the new direction of the Center for Medicaid and Medicare Innovation : Read More
October 11, 2017	Durable Medical Equipment Medicare Administrative Contractor (DMEMAC) response to Alliance September 2017 letter to clarify issues in the Surgical Dressing LCD : Read More
September 11, 2017	Comments on the proposed CY 2018 Hospital Outpatient Prospective Payment System : Read More
September 11, 2017	Comment on the proposed CY 2018 Physician Fee Schedule : Read More
September 11, 2017	Letter to the DMEMACs requesting clarifications on surgical dressing LCD (L33831) : Read More
August 21, 2017	Comments to CMS CY Updates to the Quality Payment Program : Read More
July 14, 2017	Comments to DMEMACs to Delay Implementation of Future Surgical Dressing LCD : Read More
June 22, 2017	Comments to Wisconsin Physician Services (WPS) draft wound care LCD : Read More
June 13, 2017	Comments to CMS' Hospital Inpatient Prospective Payment System; FY 2018 Rates for Acute Care Hospitals and the Long-Term Care Hospitals : Read More
May 1, 2017	Testimony at Wisconsin Physician Services (WPS) public meeting convened to collect comments on draft wound care LCD : Read More
March 9, 2017	Comments to First Coast Service Option draft LCD on wound care (DL37166) : Read More
March 9, 2017	Comments to Novitas Solutions draft LCD on wound care (DL35125) : Read More
March 9, 2017	Comments to Novitas Solutions draft LCD on treatment of varicose veins of the lower extremities (DL34924) : Read More
February 16, 2017	Testimony at FCSO public meeting on draft wound care LCD : Read More
January 26, 2017	Testimony at public meeting on draft Novitas LCD on wound care : Read More
2016
December 19, 2016	Comments on MACRA final rule guiding MIPS and APMs : Read More
November 21, 2016	Comments to FDA's General & Plastic Surgery Devices Panel of the Medical Devices Advisory Committee supporting classification of antimicrobial wound care products as Class II with special controls. : Read More
October 24, 2016	Comments to FDA draft guidance on "Use of Real World Evidence to Support Regulatory Decision-making for Medical Devices" : Read More
September 27, 2016	Comments to FDA draft guidance "Homologous Use of Human Cells, Tissues, and Cellular and Tissue-Based Products" : Read More
September 27, 2016	Comments to FDA draft guidance "Minimal Manipulation of Human Cells, Tissues, and Cellular and Tissue-Based Products" : Read More
September 12, 2016	Comments to FDA draft guidance "Minimal Manipulation of Human Cells, Tissues, and Cellular and Tissue-Based Products" (2) : Read More
September 6, 2016	Comments to CMS regarding the CY2017 Hospital Outpatient Prospective Payment System : Read More
September 6, 2016	Comments on the CY2017 Physician Fee Schedule : Read More
September 1, 2016	Comments to FDA's General and Plastic Surgery Panel of the Medical Devices Advisory Committee : Read More
August 29, 2016	Comments on proposed changes to the Medicare Appeals Process : Read More
August 25, 2016	Comments to CY 2017 Home Health Prospective Payment System Rate Update : Read More
August 12, 2016	Comments on CMS Patient Relationship Categories and Codes : Read More
August 8, 2016	Comments to Cigna Government Services Local Coverage Determination (LCD) for Application of Skin Substitute for Wounds of Lower Extremities (DL36690) : Read More
August 5, 2016	Comments to Noridian Local Coverage Determination (LCD) for Hyperbaric Oxygen (HBO) Therapy (DL 36686) : Read More
August 3, 2016	Comments to AHRQ regarding Treatment Strategies for Patients with Lower Extremity Chronic Venous Disease : Read More
May 9, 2016	Comments to CMS on Medicare Program; Part B Drug Payment Model : Read More
March 1, 2016	Comments on MACRA Episode Groups : Read More
March 1, 2016	Comments to CMS on CMS Quality Measure Development Plan : Read More
February 19, 2016	Comments on the Medicare Administrative Contractors (MAC) contracting process : Read More
January 7, 2016	Letter to DMEMAC medical directors requesting that the LCDs for pneumatic compression devices conform to the binding national coverage determination : Read More
2015
December 10, 2015	Comments to National Government Services on Debridement of Wounds (DL 33614) : Read More
November 27, 2015	Comments to Palmetto GBA on Local Coverage Determination (LCD) for Application of Skin Substitutes to Lower Extremity Chronic Non Healing Wounds (DL364166) : Read More
November 22, 2015	Comments to First Coast on LCD for Hyperbaric Oxygen Therapy (DL36504) : Read More
November 16, 2015	Presentation at meeting with CMS leadership on concerns with 2015 pneumatic compression LCD : Read More
November 5, 2015	Letter to DMEMACs regarding concerns on 2015 pneumatic compression LCD : Read More
November 5, 2015	Comments to Novitas on LCD for Strapping (DL36423) : Read More
November 2, 2015	Letter to CMS leadership regarding concerns on 2015 pneumatic compression LCD : Read More
October 13, 2015	Presentation at Palmetto GBA public meeting on LCD for Application of Skin Substitutes to Lower Extremity Chronic Non Healing Wounds (DL364166) : Read More
September 21, 2015	Comments to DMEMACs on draft surgical dressings LCD : Read More
September 2, 2015	Comments to CMS on Physicians Fee Schedule : Read More
August 31, 2015	Comments to CMS on CY2016 Hospital Outpatient Prospective Payment System proposed regulation : Read More
August 26, 2015	Testimonies from Marcia Nusgart and Alliance member Kara Couch at the DMEMAC Surgical Dressing LCD Public Meeting : Read More
July 23, 2015	Comments to Palmetto draft Local Coverage Determination (LCD) for Application of Skin Substitutes to Lower Extremity Chronic Non Healing Wounds (DL36123) : Read More
July 17, 2015	Letter to Senators Chuck Grassley (R-IA) and Charles Schumer (D-NY) and Representatives Renee Ellmers (R-NC) and Diana DeGette (D-CO) in support of the Helping Ensure Life- and Limb-Saving Access to Podiatric Physicians (HELLPP) Act (HR 1221 / S 626) : Read More
July 9, 2015	Comments to Novitas Solutions Draft Local Coverage Determination (LCD) for Hyperbaric Oxygen (HBO) Therapy (DL35021) : Read More
May 23, 2015	Comments to First Coast Service Option regarding draft Local Coverage Determination (LCD) for Application of Skin Substitute Grafts for Treatment of DFU and VLU of Lower Extremities (DL36013) : Read More
May 9, 2015	Alliance response to DMEMAC and PDAC letter on non-covered surgical dressing article : Read More
April 22, 2015	Letter to Novitas to clarify issues in final skin substitute policy Tags: Medicare Administrative Contractors (MACs), CTPs/(skin substitutes), LCD : Read More
April 15, 2015	Alliance second letter to DMEMAC and PDAC on non-covered surgical dressing article : Read More
February 25, 2015	Alliance Letter to DMEMACs PDAC non-covered surgical dressing article : Read More
February 23, 2015	Comments to FDA Minimal Manipulation of Human Cell, Tissues, and Cellular, and Tissue-Based Products guidance document : Read More
February 5, 2015	Letter to Energy and Commerce Committee in support of disposable medical technology in the 21st Century Cures discussion draft bill : Read More
2014
December 26, 2014	Comments to CMS on CY 2015 Hospital Outpatient Prospective Payment System Final Rule : Read More
December 22, 2014	Comments to CMS on CMS-1612-FC: CY 2015 Physician Fee Schedule Final Rule : Read More
November 6, 2014	Comments to Novitas on draft skin substitute policy : Read More
October 13, 2014	Letter to DMEMACs on clinical issue concerns related to pneumatic compression LCD : Read More
October 6, 2014	Letter to CMS regarding concerns on pneumatic compression LCD : Read More
September 4, 2014	Comments to Cahaba Government Benefit Administrators®, LLC draft LCD regarding Ultrasound Therapy for Wounds (DL 35300) : Read More
September 2, 2014	Comments to CY 2015 Physician Fee Schedule : Read More
September 2, 2014	Comments to CY 2015 Hospital Outpatient Prospective Payment System : Read More
August 29, 2014	Comments to CMS on CY 2015- Update to Home Health Agency PPS- Face to Face Requirement (CMS- 1611-P) : Read More
August 25, 2014	Alliance comments to Palmetto draft LCD on Debridement of Wounds (DL 35415) : Read More
July 30, 2014	Alliance comments to the DME MACs regarding Request for Information: Medical Grade Honey as a Surgical Dressing Component : Read More
July 25, 2014	Alliance comments to First Coast Service Options on draft LCD-DL35384 - Application of Bioengineered Skin Substitutes for the Treatment of Diabetic and Venous Stasis Ulcers of the Lower Extremities : Read More
July 25, 2014	Alliance comments to CMS on Prior Authorization Process for Certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Items : Read More
July 16, 2014	Alliance comments to AHRQ on Negative Pressure Wound Therapy Technologies for Chronic Wound Care in the Home Setting : Read More
May 20, 2014	Alliance comments summary at May 20 2014 HCPCS Public meeting : Read More
March 6, 2014	Alliance comments to Novitas Solutions for Local Coverage Determination on Hyperbaric Oxygen Therapy : Read More
February 14, 2014	Alliance letter for CMS’ Hospital Outpatient Panel meeting : Read More
January 27, 2014	Alliance comments to CMS on CY2014 Hospital Outpatient Prospective Payment System Final Rule : Read More
January 9, 2014	Alliance letter to Cochrane Collaboration Regarding Recent Wound Care Review : Read More
2013
December 30, 2013	Alliance Response to Milliman Care Guidelines Email and Letter Including Attachments - Exhibit A, Exhibit B, Exhibit C : Read More
November 7, 2013	Alliance comments to Novitas Solutions on Wound Care and Bioengineered Skin Substitutes : Read More
September 6, 2013	Alliance comments to CMS on CY2014 Hospital Outpatient Prospective Payment System [Attachment A, Attachment B] : Read More
July 18, 2013	Alliance sends letter of concern to Milliman Care Guidelines (MCG) on inaccuracy of its guidelines on intermittent pneumatic compression : Read More
July 18, 2013	Alliance comments to Novitas Solutions on Wound Care and Bioengineered Skin Substitutes : Read More
June 24, 2013	Alliance comments to CMS on Inpatient Prospective Payment System : Read More
April 29, 2013	Alliance comments Cigna Government Services on CTPs : Read More
March 19, 2013	Alliance comments to First Coast on Cellular and/or Tissue Derived Products for Wounds (CTPs) : Read More
January 27, 2013	Alliance comments to CMS on coverage with evidence development : Read More
2012
December 31, 2012	Alliance comments to CMS regarding G codes as part of the Physician’s Fee Schedule : Read More
September 4, 2012	Alliance comments to CMS on the Physician’s Fee Schedule : Read More
August 10, 2012	Alliance Letter to Congress to support Equity and Access for Podiatric Physicians Under Medicaid Act (S. 1309 / H.R. 3364) : Read More
July 12, 2012	Alliance comments to Noridian on draft LCD on skin substitutes : Read More
June 29, 2012	Alliance thank you letter to AHRQ for meeting about draft technology assessment on skin substitutes : Read More
June 25, 2012	Alliance comments to CMS on Inpatient Hospital Prospective Payment System : Read More
February 1, 2012	Letter to Acting Administrator Tavenner thanking her for meeting on NPWT supplier accreditation checklist : Read More
January 17, 2012	Comments to AHRQ on skin substitute technology assessment : Read More
2011
November 1, 2011	Letter to National Correct Coding Initiative requesting changes in current billing edits to ensure appropriate wound care delivery : Read More
November 1, 2011	Comments to AHRQ on venous stasis ulcer comparative effectiveness review : Read More
October 7, 2011	Submitted wound care quality measures to CMS : Read More
October 3, 2011	Letter to Congressional Committees of Jurisdiction regarding the need for CMS to use quality standards for suppliers in competitive bidding : Read More
September 23, 2011	Comments to DMEMAC medical directors medical directors on suction pump draft LCD : Read More
September 23, 2011	Comments to DMEMAC medical directors on pneumatic compression draft LCD : Read More
August 30, 2011	Presented powerpoint at DMEMAC public meeting regarding Pneumatic compression draft LCD : Read More
August 30, 2011	Comments to CMS on Physicians fee schedule : Read More
July 21, 2011	Comments to AHRQ on “Methods Guide for Effectiveness and Comparative Effectiveness Review: Avoiding Bias in Selecting Studies” : Read More
July 8, 2011	Comments to AHRQ on “Engage Stakeholders to Identify and Prioritize Future Research Needs : Read More
June 6, 2011	Comments to CMS on proposed rule on Accountable Care Organization : Read More
March 31, 2011	Letter Submitted to CMS “Draft Negative Pressure Wound Therapy Quality Standards for Suppliers” to be used in the second round of competitive bidding : Read More
2010
December 17, 2010	Comments to Cahaba on the Draft LCD for Bioengineered Skin Substitutes (DL31428) : Read More
October 15, 2010	Recommendations to the National Health Care Quality Forum Strategy & Plan : Read More
October 15, 2010	Comments to Pinnacle on the Draft LCD for Skin Substitute Use in Lower Extremities Chronic Ulcers (DL31385) : Read More
August 31, 2010	Comments to CMS on CY2011 Proposed Changes to the Hospital Outpatient Prospective Payment System and CY 2011 Payment Rules (CMS-1504-P) : Read More
August 24, 2010	Comments to CMS on the Proposed Payment Policies Under the Physician Fee Schedule CY 2011 (CMS-1503-P) : Read More
April 12, 2010	Comments to Trailblazer on Draft LCD for Bioengineered Skin Substitutes 4S-162AB : Read More
April 7, 2010	Comments to NHIC, Corp. on Draft LCD for Biologic Products for Wound Treatment and Surgical Interventions DL29867 : Read More
February 24, 2010	Comments to National Government Services on LCD for Debridement Services DL27373 : Read More
2009
September 11, 2009	Comments on LCD for Wound Care GSURG051 : Read More
July 9, 2009	Testimony and Comments at CMS' HCPCS Public Meeting on Negative Pressure Wound (NPWT) Devices : Read More
June 19, 2009	Alliance comments to CMTP on Devices for Local Treatment of Chronic Wounds EGD : Read More
May 21, 2009	Alliance comments to CMTP on Devices for Local Treatment of Chronic Wounds EGD : Read More
April 13, 2009	Comments to Trailblazer Draft LCD on Bioengineered Skin Substitutes : Read More
April 6, 2009	Comments to First Coast Draft LCD on Skin Substitutes : Read More
February 2, 2009	Letter to CMS on HCPCS codes for NPWT devices : Read More
2008
December 3, 2008	Comments on Wisconsin Physician Services Draft LCD on Wound Care : Read More
September 28, 2008	Comments to CMS on Potential Topics for Future National Coverage Determinations : Read More
September 2, 2008	Comments on Proposed Changes to HOPPS : Read More
August 29, 2008	Comments on Physician Fee Schedules : Read More
June 13, 2008	Comments on Proposed IPPS Changes : Read More

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