Submitted Comments

August 21, 2017
The Alliance submitted comments to CMS addressing the agency’s proposed updates to the Quality Payment Program (CMS-5522-P).  Comments focused on the lack of relevant quality measures addressing the needs of wound care clinicians. The Alliance suggested that the creation of additional wound care quality measures is necessary to ensure continued quality care. Comments supported the use of QCDRs and the ability of all eligible clinicians to use the QCDR option for reporting.
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July 14, 2017
The Alliance submitted comments to the DMEMAC medical directors requesting that the future Surgical Dressing LCD (L33831) be withdrawn. The Alliance outlined ways in which the LCD undermined clinical judgment and imposed unnecessarily strict frequency limitations on all dressings. The Alliance noted in its comments that the LCD and accompanying policy article do not conform to current clinical practice, lack clarity and contain conflicting language leading to confusion in wound care practice of the clinical community. 
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June 22, 2017
The Alliance submitted comments to Wisconsin Physician Services’ (WPS) draft wound care LCD (DL37228). Comments focused on utilization parameters for debridement, utilization parameters for negative pressure wound therapy (NPWT) and other areas. The Alliance noted that the policy lacks a foundation in medical evidence or clinical practice. The Alliance also pointed to inaccuracies and confusing/conflicting language in the LCD. 
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June 13, 2017
The Alliance submitted comments to CMS’ Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Fiscal Year 2018 Rates (CMS-1677-P). Comments advocated for the removal of ulcer measure NQF #0678, replacing it with a modified version of the measure entitled, “Changes in Skin Integrity Post Acute Care: Pressure Ulcer: Injury.” Comments also expressed the need for clarification on terminology used throughout the regulation related to pressure ulcers and injuries. The Alliance supported the proposed adoption of four malnutrition eCQMs measures.
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May 1, 2017
The Alliance provided oral testimony at the Wisconsin Physician Services (WPS) public meeting on its draft wound care LCD (DL37228). The Alliance voiced concern that WPS has created arbitrary parameters without clinical or scientific basis. In its submitted comments, the Alliance requested that WPS provide the evidence for the utilization parameters identified with respect to debridement as well as Negative Pressure Wound Therapy (NPWT).
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March 9, 2017
The Alliance submitted comments to FCSO’s wound care draft LCD (DL37166). Comments noted that the LCD lacked a foundation in medical evidence and clinical practice guidelines in regards to utilization parameters for both debridement and NPWT. Furthermore, the Alliance noted that the LCD lacks sufficient evidence for the change in coverage for disposable negative pressure (dNPWT) products.  The Alliance expressed concerned that FCSO may be using problematic proprietary claims data as a rationale in crafting this policy. The comments also pointed to inaccurate information and confusing/conflicting language found throughout the policy.
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March 9, 2017
The Alliance submitted comments to Novitas Solutions on wound care draft LCD (DL35125). Comments noted that the LCD lacks compelling medical evidence and clinical practice guidelines support for the utilization parameters proposed for debridement and negative pressure wound therapy (NPWT). The Alliance also expressed concern about the changes in coverage for disposable NPWT (dNPWT). The comments point out that FCSO may be relying on problematic proprietary claims data as a main source in crafting the draft regulation. The comments also note inaccurate information and confusing/conflicting language found throughout the policy.
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March 9, 2017
The Alliance submitted comments to Novitas Solutions on draft LCD (DL34924) regarding the treatment of varicose veins of the lower extremities. Alliance comments support those submitted by the American College of Phlebology and the American Venous Forum and Society of Vascular Surgeons.  Each of these groups expressed concern that the proposed regulation arbitrarily limits access to care for patients with clinically significant disease and selectively applies certain clinical practice guidelines while ignoring others. The Alliance expressed concerns that the draft LCD goes against prior LCDs from other Medicare administrative contractors (MACs) as well as most commercial carriers.
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February 16, 2017
The Alliance provided oral testimony at the FCSO public meeting on wound care LCD (DL37166). Testimony focused on: the lack of coverage for disposal negative pressure wound therapy (dNPWT); utilization parameters proposed for NPWT; utilization guidelines that limited debridement; and concerns with policies surrounding the application of Unna Boots or a multi-layer compression system. 
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January 26, 2017
The Alliance provided oral testimony at the Novitas Solutions public meeting convened to collect feedback on its wound care LCD (DL35125). Alliance testimony focused on several key issues: the lack of coverage for disposal negative pressure wound therapy (dNPWT); utilization parameters proposed for NPWT that are not based on evidence or clinical practice; utilization guidelines that limited debridement; and concerns with policies surrounding the application of Unna Boots or a multi-layer compression system. 
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