Submitted Comments

Items Related to CMS

March 1, 2016

Comments on MACRA Episode Groups

The Alliance submitted comments to CMS on MACRA Episode Groups. In its comments, the Alliance reported that chronic wounds and ulcers are reaching epidemic proportions in the United States. Despite their prevalence, this problem remains off the CMS radar screen even though Medicare will devote at least $30 billion dollars to their treatment this year (and by some estimates, twice that amount). The Alliance urged CMS to create episodes of care around the following high resource use conditions:
  • Diabetic foot ulcers
  • Venous stasis ulcers
  • Stage 3 and 4 pressure ulcers
View alliance comment
March 1, 2016

Comments to CMS on CMS Quality Measure Development Plan

The Alliance submitted comments to CMS on its Quality Measure Development Plan. The Alliance emphasized chronic wound care’s significant economic burden to Medicare and other health care payers. The Alliance encouraged CMS to also adopt measures used in Qualified Clinical Data Registries (QCDR) while also utilizing those under PQRS.
VIEW ALLiance Comment
February 19, 2016

Comments on the Medicare Administrative Contractors (MAC) contracting process

The Alliance submitted comments to CMS on the Medicare Administrative Contractors (MAC) contracting process. Comments noted that CMS failed to describe what “exceptional MAC performance” means and how that will be measured. The Alliance recommended that CMS be required to provide the metrics on how the contractors are being measured, as transparency would help clinicians and other stakeholders who interact with the Medicare Administrative Contractors (MACs). 
view alliance comment
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