Submitted Comments

November 1, 2011
The Alliance submitted a letterto the Medical Director of the National Correct Coding Initiative (NCCI) requesting changes to the Correct Coding Edits for physicians and for the Medicare hospital outpatient Prospective Payment System (PPS) for select procedures related to the treatment of complex wounds[e.g. venous, arterial, diabetic and pressure ulcers and complicated surgical wounds]. The letter noted that current edits "are impeding delivery of evidence-based treatment for these wounds and forcing increased numbers of provider visits to provide the appropriate care for their patients. We believe this is more costly to the Medicare system and needs to be corrected." The letter outlined specific recommended changes to address these concerns.

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