June 4, 2020

Letter to MACs addressing payment policies for home care, assisted living and nursing homes

The Alliance submitted a letter to three Medicare Administrative Contractors (MACs) addressing payment policies for services provided in the home (POS 12), assisted living facilities (POS 13), and nursing facilities (POS 32). In comment to Palmetto, National Government Services (NGS) and Wisconsin Physician Services (WPS), the Alliance suggested that for practitioners providing wound care  in these sites, application of cellular and/or tissue products for skin wounds (CTPs) and disposable negative pressure wound therapy services be paid at the applicable Medicare physician non-facility rate. "We submit that Policy Manual provisions along with the waivers that have been issued support our request…We are concerned that [MACs] have not been covering these services in these settings, even though there is a dire need to provide care to these patients.  Enabling payment of these proven wound care therapies (already covered by Medicare) would allow access to care while reducing the risk of COVID transmission for vulnerable wound care beneficiaries," the Alliance wrote. 
Letter to Palmetto
Letter to NGS
Letter to WPS
May 29, 2020

Comments to CMS COVID-19 Public Health Emergency Interim Final Rule

The Alliance has continued our proactive wound care advocacy with CMS surrounding the waivers and flexibilities implemented in policies addressing medical care amid the COVID-19 crisis. In comments to CMS's Interim Final Rule, the Alliance supported the Agency’s implementation of many policies while also pursuing clarification on several specific provisions that we'd flagged in our April 6th letterto the Agency that still have not been addressed. These included advocacy on issues related to surgical dressing benefits, negative pressure wound therapy billing, CTP co-pays, reimbursement and increased access for alternative methods of debridement, documentation requirements,  and more. The Alliance provided specific policy recommendations and requested that CMS add to its series of upcoming "Office Hours" teleconferences a call specific to wound care as well as one for DME suppliers/providers and manufacturers of medical equipment.
Read Alliance comments
April 6, 2020

Letter to CMS Requesting Temporary Regulatory Waivers

In response to the COVID-19 crisis, the Alliance has continued our proactive wound care advocacy by sending our letter to Secretary Alex Azar, Administrator Seema Verma and their staff requesting temporary regulatory waivers to give flexibility to wound care clinicians to provide necessary procedures and products to treat their patients amid the evolving realities of the pandemic. The  Alliance identified specific regulatory provisions related to site of service, reimbursement, documentation, DME access and other issues that, with regulatory relief, could remove barriers to treat wound care patients efficiently and effectively during this pandemic while at the same time keeping them as safe as possible while they receive the necessary care.
READ ALLIANCE LETTER
March 20, 2020

Alliance Position Statement: Avoid Unintended Consequences for Wound Patients Amid COVID-19 Pandemic Response

As hospitals and health systems are directed to halt all elective and “non essential” services as part of COVID-19 response, a concerning number have categorized wound care services and procedures as “non essential” – leaving a fragile cohort of chronic wound patients at risk. The Alliance developed a position statement to help health systems and providers avoid unintended consequences for wound patients amid the realities of the COVID-19 pandemic: “Wound Care is an Essential, Not Elective, Service that Prevents Hospital Admissions and ED Visits Among a Fragile Cohort of Patients at High-Risk of Mortality from COVID-19.”
See Alliance COVID-19 Resources for Wound Care
READ FULL STATEMENT 

logo
Follow us on:
linkedin