Submitted Comments
August 18, 2021
The Alliance submitted letters to Congress supporting the Lymphedema Treatment Act (H.R. 3630), legislation that would provide comprehensive Medicare coverage for the treatment of patients with lymphedema or for the prevention of venous stasis ulcers resulting from venous insufficiency. "Lack of access to the clinically recognized treatments necessary to best care for these conditions leads to higher costs and poorer health outcomes, including recurrent infections, progressive degradation in condition, and, too often, disability," wrote the Alliance, recommending that Congress grant CMS the statutory authority to cover compression garments under the Medicare benefit.
August 10, 2021
On August 5, 2021, the Alliance submitted letters of support to for S. 2363 and its companion bill H.R.2356, both named the Better Wound Care at Home Act. Currently, implementation of the Medicare home health benefit for disposable negative pressure wound therapy (NPWT) limits patient access to this technology by imposing cumbersome billing regulations on the home health agencies (HHAs) and nurses who deliver care. By streamlining billing for HHAs onto the industry-standard claims form, eliminating burdensome time reporting requirements on home health nurses, and clarifying that payment to HHAs for disposable NPWT is for the device only, this legislation will improve access to a cost-effective, high-quality treatment for chronic wounds.
August 6, 2021
In advance of the Advisory Panel on Hospital Outpatient Payment public meeting on Aug. 23, 2021, the Alliance submitted written comments on specific provisions addressing payment for Cellular and/or Tissue Based Products for Skin Wounds (CTPs) and provided recommendations regarding CPT add-on codes and assignment of Ambulatory Payment Classifications (APCs) for the same size wound.
July 7, 2021
The Alliance delivered oral comments at the July 7, 2021 HCPCS Public Meeting for Non-Drugs and Non-Biologicals to elevate concerns about the CMS preliminary coding decision to defer applications from CTP ("skin substitute") products to a subsequent coding cycle. "Both the Alliance’s clinical associations and business entity members are concerned since this delay in decision making is impacting the commercialization of these products which can be devastating to small companies. For our clinician members, the delay in getting these products to market hampers their ability to use them as one of the treatments for their patients," the Alliance stated.
June 29, 2021
The Alliance submitted a letter to the National Correct Coding Initiative (NCCI) contractor requesting the elimination of the NCCI edit for Total Contact Casting, Multi-layer Compression, as well as Unna Boot paste casts for both the Physician and the Hospital Outpatient Payment areas. We voiced concerns that the edits are inconsistent with peer-reviewed literature and do not allow the accurate identification and allocation of resources for the clinical procedures provided to deliver the most effective clinical approaches for treatment of diabetic foot ulcers and venous ulcers. We asked that these changes be implemented as soon as the October 1, 2021 update of the NCCI edits. The Alliance letter included a clinical review of the published literature on these procedures and a summary of the existing evidence to support the elimination of these edits.
June 15, 2021
The Alliance submitted comments to CMS' CY 2022 Hospital Inpatient Prospective Payment System (IPPS) supporting adoption of wound care related quality measures and specifically advocating for inclusion of the Global Malnutrition Composite Score, NQF #3592.
April 16, 2021
The Alliance submited comments to CMS' Interim Final Rule regarding Medicare Coverage of Innovative Technology (MCIT) and the definition of “Reasonable and Necessary.” The Alliance encouraged CMS to move forward with select portions of the rule without additional delay, and provided feedback to specific questions posed by the Agency. However, the Alliance also reiterated its concern that the MCIT rule and the rule addressing the new definition of “reasonable and necessary” are two very distinct and separate topics of focus that should never have been issued together.
April 13, 2021
The Alliance submitted a letter to the National Quality Forum's Prevention and Population Health Endorsement Committee in support of the inclusion of MUC20-0032, the Global Malnutrition Composite Score, in CMS' Hospital Inpatient Quality Reporting (IQR) program. This letter is a follow-up to our initial January 2021 letter endorsing the composite measure to continue advocacy to move the adoption process forward.
March 23, 2021
Over the past four years, CMS has placed the issue of reforming the CTP payment methodology in the Hospital Outpatient Prospective Payment System (OPPS) proposed/final rules, soliciting feedback on Episodic Payment, Single APC, and Comprehensive APC. In March, the Alliance developed and proactively submitted to CMS its recommendations regarding CTP payment methodology for the Agency to consider as it begins development of proposed rules for CY 2022. In summary, the Alliance encouraged CMS to propose a CTP/skin substitute payment methodology for CY 2022 implementation that collapses the “high cost” and “low cost” products, allows separate payment for the add-on codes, and tracks the base codes and add-on codes to unique APC Groups which are updated annually. See detailed recommendation in CMS letter, below.
March 15, 2021
When Noridian issued a draft wound care local coverage determination (LCD) in February, the Alliance quickly mobilized to provide feedback and recommendations to shape the final policy. Ensuring that this draft was correct clinically is important to Alliance members since it could be used by other AB MACs in the future. The draft policy as issued was well-rounded and reflected some of the feedback previously provided by the Alliance to Noridian. However, the policy also included a significant number of areas with inaccurate information, outdated terminology, and, in several cases, inconsistent or conflicting language. The Alliance convened a workgroup to bring together the broad expertise of our membership to develop extensive comments to both the draft LCD and its accompanying policy article (LCA).
