News Releases & Publications

Sept. 19, 2022 – The Alliance of Wound Care Stakeholders urged the Centers for Medicare and Medicaid Services to update inadequate payment methodologies for cellular and/or tissue-based products for skin wounds (CTPs, or “skin substitutes”) to ensure appropriate access to care in the hospital outpatient/provider-based department (PBD) site of service. In comments submitted to CMS’s proposed 2023 Hospital Outpatient Prospective Payment System updates, the Alliance forwarded specific recommendations to correct policy and payment challenges that are negatively impacting access to CTPs in provider-based departments. These include...
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Sept. 13, 2022 - The Alliance of Wound Care Stakeholders, the leading voice for wound care advocacy and education to address public policy issues impacting patient access to care, marks two decades of experience in addressing many issues of commonality for its members that include clinical and patient associations, wound care clinics and business entities spanning manufacturers and distributors, providers, researchers and reimbursement experts. The Alliance takes pride in its role as a key collaborator and resource for numerous government agencies, providing insights and guidance on issues impacting coding, coverage and payment, as well as quality measures and wound care research. “As we look back on our 20 years of serving multiple stakeholders across the wound care community, we are gratified to reflect on significant advocacy and educational outreach activities in the regulatory, legislative and public arenas,” says Marcia Nusgart, R.Ph., CEO, The Alliance. 
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Sept. 7, 2022 - The Alliance alerted the Centers for Medicare and Medicaid Services (CMS) that changes to the way cellular and/or tissue-based products for skin wounds (CTPs, or “skin substitutes”) are coded and paid for in the physician office under the proposed 2023 Physician Fee Schedule will create barriers to care that could ultimately lead to increased amputations and infections for patients with chronic non-healing wounds. The Alliance urged CMS to delay implementation of the proposed provisions until patient access issues can be further studied. “Under the proposed 2023 policy, payments for CTPs and their application will simply not cover the costs to physician offices. Without adequate reimbursement, many physicians will no longer be able to afford to provide these medically necessary and successful advanced treatments to their patients. This would deprive patients these valuable treatment options which, in turn, could ultimately result in an increase in infections as well as amputations," the Alliance told CMS in submitted comments.
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September 2021 – The Alliance of Wound Care Stakeholders voiced opposition to payment cuts that would negatively impact wound care providers and their patients in recent comments to the Center for Medicare and Medicaid Services’ (CMS) proposed CY2022 Physician Fee Schedule and proposed Hospital Outpatient Prospective Payment System (HOPPS) regulations. The Alliance challenged cuts to surgical procedures, physical therapy services, disposable negative pressure wound therapy and compression payment as well as provided recommendations to remove barriers to CTPs. The final regulations from CMS are expected to issue in November.
See Alliance News Release
August 26, 2021 – At its public meeting on August 23, the Advisory Panel on Hospital Outpatient Payment unanimously approved two recommendations made by the Alliance of Wound Care Stakeholders that, if accepted and implemented by CMS, would positively impact wound care by correcting flaws in the payment that have negatively impacted reimbursement for cellular and tissue-based products for wounds (CTPs, also known as skin substitutes) and removing barriers to access for these important wound care products. While the Advisory Panel submits recommendations to CMS for consideration, the Agency is not obligated to move its recommendations forward. That is why now is the time for the wound care community to make its voice heard to CMS so that these recommendations are included in the OPPS policy as it is revised and finalized. Here's how.

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October 2020 - The Center for Medicare and Medicaid Services’ (CMS) Durable Equipment Medical Administrative Contractors (DMEMACs) updated its “Local Coverage Article: Surgical Dressings” to include payment for secondary, as well as primary, use of alginate and other fiber gelling dressings. Prior to the October 15, 2020 Policy Article Update (A54563), these products were only reimbursed when used as primary dressings - limiting healthcare providers’ discretion and choices in properly treating their wound patients.
Read Alliance News Release

October 2020 – In comments submitted to the Center for Medicare and Medicaid Services (CMS), the Alliance of Wound Care Stakeholders voiced its opposition to payment cuts from five to nine percent for surgical procedures and nine percent for physical therapy services as CMS proposes in its CY2021 Physician Fee Schedule. The Alliance also called on CMS to (1) Adopt all of the American Medical Association’s RUC recommendations including updated E/M values in procedure codes with 10- and 90-day global periods; (2) Maintain a patient’s home as an originating site even when the public health emergency expires; (3) Include additional telehealth codes for physical therapy services, and more.

Additionally, in comments submitted to CMS' CY2021 Hospital Outpatient Prospective Payment System proposed updates, the Alliance flagged concerns with provisions dealing with coding and payment for Cellular and/or Tissue based Products for skin wounds (CTPs, also known as skin substitutes). The Alliance supported inclusion of synthetic CTPs in the definition of “skin substitutes” but expressed significant concerns with the Agency’s proposed establishment of a unique C code to define an entire class of non-branded products and the placement of these products in the OPPS high cost payment package.
See Alliance News Update Summarizing Comments

The Center for Medicare and Medicaid Services released in early August its proposed CY 2021 updates to the Hospital Outpatient Prospective Payment System and Physician Fee Schedule. The Alliance has identified several of the provisions most relevant/impactful to wound care clinicians. The Alliance will be vetting these policies with its membership and developing comments and recommendations to submit to the Agency. 
READ THE ALLIANCE ADVOCACY UPDATE - SUMMARY OF RELEVANT PROVISIONS

July comments to CMS are the latest in a series of Alliance actions to ensure that clinicians can treat patients efficiently and effectively, with appropriate reimbursement

July 2020 - The Alliance of Wound Care Stakeholders called on the Centers for Medicare and Medicaid (CMS) to expand and increase reimbursement for wound-care related telehealth visits; provide flexibility in documentation requirements for continued need and refill of surgical dressings and other supplies; and permit medically necessary procedures to take place on the same date of service so that quality care to be provided to patients while minimizing their risk of COVID-19 exposure.These and other requests were made in the Alliance’s July “Comments to CMS Covid-19 Public Health Emergency Second Interim Final Rule.”  The Alliance’s July recommendations to CMS address wound-relevant issues including:

  • Temporary relocation site billing
  • Waive standard written order (SWO) provisions in select local coverage determinations (LCD)
  • Allow billing for dNPWT telehealth
  • Allow total contact casting (TCC) to be provided on the same date of service as other procedure

READ ALLIANCE NEWS RELEASE
See Alliance Comments to CMS

Three wound care quality measures developed by the Alliance of Wound Care Stakeholders and the US Wound Registry (USWR) are now included on Centers of Medicare and Medicaid Services’ (CMS) Physician Compare website, following a summertime content update that expanded quality performance data on the site. The USWR quality measures selected for Physician Compare reporting are:

  1. “Adequate off-loading of diabetic foot ulcer at each treatment visit.”
  2. “Adequate compression of venous leg ulcers at each treatment visit.”
  3. “Vascular assessment of patients with chronic leg ulcers.”
READ ALLIANCE NEWS RELEASE

 

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