Submitted Comments
September 24, 2018
The Alliance submitted comments to CMS in response to its proposed CY 2019 Hospital Outpatient Prospective Payment System (PPS) and Ambulatory Surgical Center Payment Systems as well as changes to the Quality Reporting Programs. The Alliance focused its comments on provisions related to:
- CTP packaging and payment methodology
- Pass through status for CTPs
- Guidelines
- Methods to control unnecessary increases in the volume of outpatient services
- Ways to control unnecessary costs
- Price transparency
September 21, 2018
The Alliance submitted a letter to United Healthcare, requesting that it delay implementation of “Commercial Medical Policy 2018T0592A, Skin and Soft Tissue Substitutes. ” The policy, which is scheduled to become effective October 1, 2018, will “cause significant disruption in the care of your members in outpatient, hospital, rehabilitation, skilled nursing and other settings who are currently receiving skin and soft tissue substitutes for the management of their chronic wounds,” the Alliance wrote. “We request a meeting with you to discuss our concerns, address issues regarding improvement in health outcomes with these therapies, and to offer recommendations that will serve to improve the clinical outcomes for your member patients at lower cost of care.”
September 10, 2018
The Alliance submitted comments to CMS' proposed CY 2019 Physician Fee Schedule supporting specific provisions to ease paperwork/documentation burdens, including:
- Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit;
- Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient
- Allowing physicians to choose between current documentation guidelines, documenting by time only, or documenting by medical decision making only
- Removing the need to justify providing a home visit instead of an office visit. However, the Alliance also used its comments to voice its strong opposition to the consolidation of Evaluation and Management codes and the corresponding reduction in payment for E/M services for those that provide the most complex care. The Alliance submitted a series of examples of unintended consequences that the proposal would create and urged CMS not to move forward with that provision.
August 7, 2018
The Alliance submitted comments addressing the AmeriHealth Caritas Clinical Policy on Full-body Hyperbaric Oxygen Therapy. While supportive of the need for safe and effective HBO and the need for policies that minimize administrative burdens while still being easy to implement and enforce, the Alliance identified clinically inaccurate and/or unsubstantiated information within the policy to be addressed as the policy is revised.
August 3, 2018
The Alliance submitted a letter to Congress supporting the Lymphedema Treatment Act (S. 498, H.R. 930). The Alliance recommended that Congress grant CMS the statutory authority to cover compression bandages and garments for lymphedema under the Medicare benefit, noting that this change could have a substantial impact via improved outcomes and quality of life, reduced costs for beneficiaries and the health care system, and decreased federal spending.
July 22, 2018
The Alliance submitted comments to CMS in response to its request for comments on Pre-Claim Review Demonstration for Home Health Services. While the Alliance understands that the rationale for bringing this failed demonstration project back is to address issues of fraud and abuse, we noted in comments that the policy would create a significant administrative burden on home health agencies. Most concerningly, it would have a tremendous negative impact on the access to care for beneficiaries in order for CMS to target a few “bad apples.”
June 24, 2018
The Alliance submitted comments that overall supported CMS’ efforts to streamline and de-duplicate measures. However, in comments to “Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Fiscal Year 2019 Rates,” the Alliance noted concerns with some of the provisions directly impacting wound care and, specifically, pressure ulcers. The Alliance recommended that CMS:
- Remove pressure ulcers (PSI 03) from the NQF #5031 Patient Safety and Adverse Events Composite Measure
- Create a stand-alone quality measure for PSI 03, Pressure Ulcer Rates
- Or, as an alternative, increase the weight currently outlined in the proposed rule for pressure ulcers.
- Implement the Equal Measure Weights approach outlined in the proposed rule.
June 5, 2018
Alliance submitted comments to WPS on its proposed Wound Care LCD that went into effect on April 16, 2018. The Alliance noted specific, significant concerns with some of the language contained in the final LCD – including clinically incorrect statements – on requested clarity on several key areas, including:
- debridement coverage for chronic non pressure ulcers
- debridement coverage for diabetic ulcers
- utilization parameters for traditional and disposable Negative Pressure Wound Therapy (NPWT)
March 2, 2018
The Alliance expressed its concern about CMS’ Hospital Harm- Hospital-Acquired Condition -Pressure Injury measure. While the Alliance supports and encourages the continued development of quality measures that assess wound care outcomes, the Alliance flagged that the intended objective will not be achieved the way this measure has been crafted. Overall, the specific language as well as the numerator and denominator, contained within this document are not accurate, wrote the Alliance in its comments. Furthermore, there are scientifically incorrect statements within this proposed measure. “It is very concerning that CMS has tied a Pressure Injury Measure to Hospital Harm. As stated throughout our comments – it is possible for a patient to develop or have a pressure ulcer without any harm. If this measure continues as a quality indicator to measure harm, there will be unintended consequences - either an increase in the number of lawsuits, or an increased likelihood that hospitals will be unable to defend themselves against frivolous litigation - despite the best care being provided.”
January 4, 2018
The DMEMACs responded to the Alliance’s December 2017 letter flagging inconsistencies between the guidance the DMEMACs provided to the Alliance in an October 2017 “clarification letter” and the instructions that Noridian gave in a November educational webinar on the surgical dressing LCD.
