Submitted Comments

September 27, 2016
The Alliance submitted comments to the FDA on its "Minimal Manipulation of Human Cells, Tissues, and Cellular and Tissue-Based Products - draft guidances for industry and FDA staff." The Alliance highlighted a number of issues with regard to "main function" and "basic function" terminology in the guidance. Comments also identified multiple inconsistencies between the "Minimal Manipulation" guidance and the "Homologous Use" guidance. The Alliance encouraged the FDA should work with stakeholders to develop an appropriate guidance document that is consistent with guidances and current regulatory language and that provides needed clarity.
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September 12, 2016
The Alliance delivered oral comments at the FDA's September 2016 Public Hearing on Draft Guidances Relating to the Regulation of Human Cells, Tissues, and Cellular and Tissue-Based Products. The Alliance express concern with the narrow definition of homologous use of amnion tissue and how that will impact wound care, as there are many basic functions of amniotic tissue that should be used for wound healing. The Alliance noted that there are many significant new requirements within the minimal manipulation document which not only conflict with the homologous use document, they conflict with current regulatory language.
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September 6, 2016
The Alliance submitted comments to CMS on the CY 2017 Hospital Outpatient Prospective Payment System noting that no measures in the Hospital Outpatient Quality Reporting program are specific to wound care. The Alliance reminded CMS that there are 21 quality measures specific to the practice of wound care, fully programmed, as electronic clinical quality measures available within the U.S. Wound Registry Qualified Clinical Data Registry. Furthermore the Alliance expressed concerns on the flawed methodology CMS uses to calculate the payment for cellular and tissue-based products for wounds (CTPs, referred to in the policy as skin substitutes).
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September 6, 2016
The Alliance submitted comments to CMS on its proposed Physician Fee Schedule update: "CMS-1654-P: Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2017; Medicare Advantage Pricing Data Release; Medicare Advantage and Part D Medical Low Ratio Data Release; Medicare Advantage Provider Network Requirements; Expansion of Medicare Diabetes Prevention Program Model." Alliance comments focused on wound care services it viewed as improperly/inaccurately valued by the fee schedule. The Alliance also called for increased transparency on how CMS will use global service data. Additional, the Alliance requested that CMS review its criteria for the expansions of the upcoming Diabetes Prevention Program model as the Medicare Diabetes Prevention Program (MDPP).
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September 1, 2016
The Alliance submitted comments to the FDA's General and Plastic Surgery Panel of the Medical Devices Advisory Committee in advance of the panel's September 2016 meeting. The Alliance emphasized that the products that are currently in the FRO category are low to moderate risk, have been in the marketplace for many years, and should be classified by the FDA into either Class I or Class II, most remaining subject to 510(k). The Alliance comments gave perspective on the issue, addressing the following:
  • An overview of wound care relating to the FRO product category
  • The science behind management of chronic wounds
  • Management of chronic wounds using antimicrobial wound care products
  • Products classified in the FRO product category, their indications for use and testing
  • Evidence for safety and effectiveness of products in FRO category/ Low-moderate risk of antimicrobial resistance
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August 29, 2016
The Alliance submitted comments to CMS’s proposed ruleMedicare Program; Changes to the Medicare Claims and Entitlement, Medicare Advantage Organization Determination, and Medicare Prescription Drug Coverage Determination Appeals Procedures.”  Comments noted the Alliance’s concern that the MACs (Medicare Administrative Contractor) and Qualified Independent Contractors (QIC) are not equipped to appropriately apply precedential decisions,” and raised concerns about many contractors’ inaccurate application of LCD and NCD criteria. The Alliance recommended that CMS create a process to review and reject outdated precedents and suggested that CMS create a process for interested parties to challenge existing precedent. Additionally, the Alliance suggested that all Medicare providers and contractors be trained and educated by CMS on the proper procedures governing precedential cases. The Alliance recommended that CMS provide its contractors with a summary of each case precedent to simplify the process of applying precedent to future appeals.
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August 25, 2016
The Alliance submitted comments to CMS on its proposed policy update “CY 2017 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements.” Alliance comments focused on the proposed rule’s implementation of the newly created statutory benefit to pay home health agencies separately for disposable Negative Pressure Wound Therapy (NPWT). The Alliance requested that the Agency clarify the section regarding payment for the time that the home health agency provides the disposable NPWT. The Alliance recommended that in addition to paying for the disposable NPWT devices, CMS also pay the home health agency the nursing time and travel for initial and subsequent visits to those patients requiring home health services who can benefit from the use of disposable NPWT.
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August 12, 2016
The Alliance submitted comments to CMS’s on its draft policy on Patient Relationship Categories and Codes. Comments noted that the proposed rule puts another burden on the clinician for tracking, coding and documentation but adds no value to patient care, or treatment outcomes. The Alliance emphasized to CMS that currently under MIPS, there are no quality measures that a wound care clinician can report for the actual wound care treatment they perform. As such, the obligatory reporting of quality, resource use, and clinical performance measures may not truly be indicative of neither the wound care work wound care practitioners do nor of the resources that they use to treat their patients. Thus, resource use for any wound care clinician will be skewed until this issue is resolved. The Alliance suggested that the Patient Relationship Categories and Codes rule be delayed at least unto 2018 or beyond to allow clinicians sufficient time to adjust to all the other MACRA and MIPS documentation and reporting changes and challenges.
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August 8, 2016
The Alliance submitted comments to Cigna Government Services (CGS) on Local Coverage Determination (LCD) for Application of Skin Substitute for Wounds of Lower Extremities (DL36690). The Alliance reminded CGS that the term “skin substitutes” is clinically inaccurate and should be replaced with more inclusive descriptor “Cellular and/or tissue based products for wounds (CTPs).” The comments addressed issues in the draft policy related to the classification of products, utilization instructions, coverage limitations and confusing language in the guidance regarding its distinction when providing coverage for diabetic foot ulcer (DFU) vs. venous leg ulcer (VLU). Comments also highlighted the need for CGS to recognize podiatrists as providers who can and do treat patients with wounds, and the indications for use (IFUs) for products affected by the LCD. 
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August 5, 2016
The Alliance submitted comments to Noridian on Local Coverage Determination (LCD) for Hyperbaric Oxygen (HBO) Therapy (DL 36686). The Alliance recommended that Noridian revise the policy to recognize the implicit coverage of skin grafts and flaps and expressed concern about the policy’s wording around adjunctive treatment of the diabetic foot ulcer (DFU). Comments also flagged several areas in the draft policy in which Noridian provided specific dose and frequency parameters that are contrary to current standards of practice. In addition, the Alliance noted that some of the evidence that Noridian has used to substantiate the provisions in this policy is outdated. 
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