Submitted Comments
As part of comments submitted to Wisconsin Physicians Service Insurance Corporation’s Draft Local Coverage Determination for Wound Care, the Alliance flagged eight key concerns and flaws within the policy that negatively impact patient care. Comments focused on WPS’ limiting coverage of debridement while not providing adequate scientific evidence to support its coverage policy. The Alliance questioned the policy’s elimination of a significant number of CPT codes related to debridement and the inclusion of only a limited number of conditions which must be present in order to provide a debridement. The Alliance also flagged many areas where the policy conflicted with other existing DMEMAC policies or violated processes in CMS’s Program Integrity Manual. These comments follow similar comments submitted to WPS in 2017, 2018 and early-2019 raising the same issues.
The Alliance submitted comments to the United States Pharmacopeia's (USP) draft Medicare Model Guidelines advocating for creation of a new subcategory for wound care products. Under the current policy, wound care products are in the “Dermatological, Other” category that includes a long list of products for a variety of conditions with varying severity, such as acne and lice treatments. The Alliance requested that the USP add a subcategory titled “wound care” under Dermatology to distinguish the chronic wound products from other subcategories in Dermatology, which would also better protect coverage of wound care products under Medicare Part D.
- The broad sweep to move all therapeutic services from direct to general supervision
- The implementation of prior authorization for procedures that are often utilized to treat chronic wounds that threaten both life and limb
- Payment methodologies for CTPs
- Lump-sum episode based payment for a wound care episode
- The single Ambulatory Payment Classification (APC) proposal and C-APC methodologies
- Inaccurate APC Group assignments for CTPs due to facilities' incorrect coding/billing, which for years has resulted in APC Group assignments that fail to reflect the true costs of the CTPs.
The Alliance submitted detailed comments to CMS on a range of provisions in the proposed Physician Fee Schedule that impact wound care providers. Comments focused on:
- Evaluation and Management Codes
- The conclusions of three RAND Corporation reports utilized in the report to support certain provisions (CMS had contracted RAND to collect data on the number and level of post-operative visits for surgical global codes provided to Medicare beneficiaries)
- Relative Value Units (RVUs) for Physical Therapy
- Practice Expense (PE) RVUs for Disposable Negative Pressure Wound Therapy (CPT Codes 97607 & 97608)
- Open Wound Debridement (CPT Codes 97597 and 97598)
- Ultrasonic Wound Assessment (CPT Code 97610)
See additional comments and recommendations submitted to CMS in the full-text Alliance comments below.
The Alliance submitted comments to CMS in response to the proposed updates in the CY 2020 Home Health Prospective Payment System. The Alliance noted concern with CMS’ proposal to reduce the Requests for Anticipated Payment (RAP), asking that CMS consider the cash flow requirements of new home health agencies who also have capitalization needs and smaller agencies and those in rural areas have a significant need for cash flow support. The Alliance also strongly opposed the removal of pain measures from the Home Health Quality Reporting Program (HH QRP) and the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS surveys). While CMS reports that elimination of the measure is in line with the agency’s broader efforts to address the opioid epidemic, the Alliance flagged that pain remains an issue that is important to patients served in the home health setting and there is no evidence to suggest that the use of these measure is linked to opioid misuse. See the Alliance's full comments to CMS below.
- NCCI edits
- HCPCS coding reform
- Local coverage decisions (LCDs) versus coverage articles (LCAs)
- Prior authorization
- Billing for disposable negative pressure wound therapy in home health care setting
- Implementation timing of rules issued by CMS
The Alliance submitted comments to AHRQ regarding its draft Technical Brief (TB) and Supplemental Evidence and Data for Systematic Reviews (SEADS) report on “Skin Substitutes for Treating Chronic Wounds.” Comments summarized the problematic procedural issues surrounding the report and raised concern that only 3 of the 83 studies submitted were accepted for consideration - excluding of most of the evidence submitted from the expanded evidence search that had deliberately been re-opened. "Stakeholders have the right to review the next version of the draft to ensure that the corrections were made, the evidence was utilized correctly and read whether any conclusions were altered as a result," emphasized the Alliance. "We urge AHRQ to release the next draft of the technical review with an additional public comment period prior to final publication."
The Alliance attended the March 11 Physician-Focused Payment Model Technical Advisory Committee (PTAC) meeting and provided comments on the PTAC proposal regarding “Bundled Payment for All Inclusive Outpatient Wound Care Services in Non Hospital Based Setting.” The Alliance complimented the PTAC’s Preliminary Review Team (PRT) on the very extensive background work that they did in preparation for this meeting. The Alliance was in agreement with the PTAC’s preliminary results that the proposal as written has a number of structural flaws and elements that were not sufficiently developed and thus should not move forward as it is currently written.
