Alliance of Wound Care Stakeholders

Submitted Comments by Year

List of articles in category Submitted Comments
Created Date Title

2022
September 23, 2022 Comments on Novitas and FCSO Draft LCD/LCA for Skin Substitutes for the Treatment of DFU/VLU
September 13, 2022 Comments to Proposed 2023 Hospital Outpatient Prospective Payment System (HOPPS)
September 6, 2022 Comments to Proposed 2023 Physician Fee Schedule
August 25, 2022 Oral Testimony on FCSO/Novitas Public Meetings on Draft LCD/LCA for Skin Substitutes for the Treatment of DFU/VLU
August 11, 2022 Comments to Proposed 2023 Home Health PPS : Read More
July 19, 2022 Letter to Congress Regarding Cuts to Physician Reimbursement : Read More
June 28, 2022 Follow-Up Comments to FDA Wound Healing Workshop
June 27, 2022 Alliance CTP Educational Seminar for CMS Directors & Senior Staff : Read More
June 14, 2022 Comments to Inpatient Prospective Payment System (IPPS) FY 2023 proposed rule : Read More
May 27, 2022 Comments to Novitas Draft LCD/LCA "Skin Substitutes for the Treatment of Diabetic Foot Ulcers & Venous Leg Ulcers" : Read More
May 27, 2022 Comments to FCSO Draft LCD/LCA on Skin Substitutes for the Treatment of Diabetic Foot Ulcers & Venous Leg Ulcers : Read More
April 29, 2022 Oral Comments on Novitas Draft LCD "Skin Substitutes for the Treatment of Diabetic Foot Ulcers & Venous Leg Ulcers" : Read More
April 28, 2022 Oral Comments Addressing FCSO Draft LCD on Skin Substitutes for the Treatment of Diabetic Foot Ulcers & Venous Leg Ulcers : Read More
April 26, 2022 Responses to Questions Posed by FDA for its April Wound Healing Scientific Workshop
April 3, 2022 Letter to NCCI and CMS : Read More
March 15, 2022 Presentation to CMS regarding impact of inconsistent HCPCS coding for CTPs : Read More
March 1, 2022 Letter requesting Congress’ help to address the steep reductions in Medicare payments : Read More
February 8, 2022 Letter to Noridian: Wound and Ulcer Care LCD/LCA : Read More
January 18, 2022 Co-signed letter to CMS urging greater transparency & uniformity in setting reimbursement for products used in office-based settings : Read More

2021
December 1, 2021 Comments at HCPCS Public Meeting : Read More
November 18, 2021 Comments to FDA supporting real-world evidence : Read More
November 9, 2021 Comments to Pneumatic Compression LCD : Read More
November 1, 2021 Comments supporting podiatry scope-of-practice legislation in Massachusetts : Read More
October 14, 2021 Alliance response to the proposed repeal of the Medicare Coverage of Innovative Technology (MCIT) rule : Read More
October 3, 2021 Follow-Up Letter to National Correct Coding Initiative (NCCI) contractor : Read More
September 17, 2021 Comments to CY 2022 Hospital Outpatient Prospective Payment System : Read More
September 15, 2021 Letter to Senate Finance Committee
September 13, 2021 Comments to CY 2022 Physician Fee Schedule : Read More
September 7, 2021 Co-signed letter to CMS opposing clinical labor pricing proposal in 2022 Physician Fee Schedule : Read More
August 23, 2021 Presentation to the Advisory Panel on Hospital Outpatient Payment : Read More
August 18, 2021 Letters to Congress Supporting the Lymphedema Treatment Act : Read More
August 10, 2021 Letters of Support for the Better Wound Care At Home Act : Read More
August 6, 2021 Comments to Advisory Panel on Hospital Outpatient Payment : Read More
July 7, 2021 Comments at HCPCS Public Meeting regarding application deferrals : Read More
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 : Read More
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 at HCPCS Public Meeting supporting need for product-specific Q codes for CTPs/skin substitutes : Read More
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)
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 (NCCI) 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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