Submitted Comments

Items Related to Debridement

November 10, 2019

Comments to WPS Draft LCD for Wound Care

As part of comments submitted to Wisconsin Physicians Service Insurance Corporation’s Draft Local Coverage Determination for Wound Care, the Alliance flagged eight key concerns and flaws within the policy that negatively impact patient care. Comments focused on WPS’ limiting coverage of debridement while not providing adequate scientific evidence to support its coverage policy. The Alliance questioned the policy’s elimination of a significant number of CPT codes related to debridement and the inclusion of only a limited number of conditions which must be present in order to provide a debridement. The Alliance also flagged many areas where the policy conflicted with other existing DMEMAC policies or violated processes in CMS’s Program Integrity Manual. These comments follow similar comments submitted to WPS in 2017, 2018 and early-2019 raising the same issues. A series of recommendations from the Alliance, addressing each of the eight key concerns, were submitted for WPS consideration as part of comments.
Read Alliance Comments

October 4, 2018

Comments to WPS Wound Care Coding Companion for Wound Care L37228

Via email, the Alliance requested clarification from WPS regarding its new A55909: Wound Care Coding Companion for Wound Care L37228. The Alliance requested the literature that WPS reviewed to eliminate coverage of specific codes related to debridement, noting that  the 21st Century Cures Act requires MACs to provide the evidence utilized in making coverage decisions or eliminating coverage. 

Read Alliance emaiL

 

June 5, 2018

Comments to WPS Wound Care LCD

Alliance submitted comments to WPS on its proposed Wound Care LCD that went into effect on April 16, 2018. The Alliance noted specific, significant concerns with some of the language contained in the final LCD – including clinically incorrect statements – on requested clarity on several key areas, including:
  •  debridement coverage for chronic non pressure ulcers
  •  debridement coverage for diabetic ulcers
  • utilization parameters for traditional and disposable Negative Pressure Wound Therapy (NPWT)

View Alliance comment
June 22, 2017

Comments to Wisconsin Physician Services (WPS) draft wound care LCD

The Alliance submitted comments to Wisconsin Physician Services’ (WPS) draft wound care LCD (DL37228). Comments focused on utilization parameters for debridement, utilization parameters for negative pressure wound therapy (NPWT) and other areas. The Alliance noted that the policy lacks a foundation in medical evidence or clinical practice. The Alliance also pointed to inaccuracies and confusing/conflicting language in the LCD. 
View Alliance Comment
May 1, 2017

Testimony at Wisconsin Physician Services (WPS) public meeting convened to collect comments on draft wound care LCD

The Alliance provided oral testimony at the Wisconsin Physician Services (WPS) public meeting on its draft wound care LCD (DL37228). The Alliance voiced concern that WPS has created arbitrary parameters without clinical or scientific basis. In its submitted comments, the Alliance requested that WPS provide the evidence for the utilization parameters identified with respect to debridement as well as Negative Pressure Wound Therapy (NPWT).
View Alliance Comment
March 9, 2017

Comments to First Coast Service Option draft LCD on wound care (DL37166)

The Alliance submitted comments to FCSO’s wound care draft LCD (DL37166). Comments noted that the LCD lacked a foundation in medical evidence and clinical practice guidelines in regards to utilization parameters for both debridement and NPWT. Furthermore, the Alliance noted that the LCD lacks sufficient evidence for the change in coverage for disposable negative pressure (dNPWT) products.  The Alliance expressed concerned that FCSO may be using problematic proprietary claims data as a rationale in crafting this policy. The comments also pointed to inaccurate information and confusing/conflicting language found throughout the policy.
View Alliance Comment
March 9, 2017

Comments to Novitas Solutions draft LCD on wound care (DL35125)

The Alliance submitted comments to Novitas Solutions on wound care draft LCD (DL35125). Comments noted that the LCD lacks compelling medical evidence and clinical practice guidelines support for the utilization parameters proposed for debridement and negative pressure wound therapy (NPWT). The Alliance also expressed concern about the changes in coverage for disposable NPWT (dNPWT). The comments point out that FCSO may be relying on problematic proprietary claims data as a main source in crafting the draft regulation. The comments also note inaccurate information and confusing/conflicting language found throughout the policy.
View Alliance Comment 
February 16, 2017

Testimony at FCSO public meeting on draft wound care LCD

The Alliance provided oral testimony at the FCSO public meeting on wound care LCD (DL37166). Testimony focused on: the lack of coverage for disposal negative pressure wound therapy (dNPWT); utilization parameters proposed for NPWT; utilization guidelines that limited debridement; and concerns with policies surrounding the application of Unna Boots or a multi-layer compression system. 
View Alliance Comment
January 26, 2017

Testimony at public meeting on draft Novitas LCD on wound care

The Alliance provided oral testimony at the Novitas Solutions public meeting convened to collect feedback on its wound care LCD (DL35125). Alliance testimony focused on several key issues: the lack of coverage for disposal negative pressure wound therapy (dNPWT); utilization parameters proposed for NPWT that are not based on evidence or clinical practice; utilization guidelines that limited debridement; and concerns with policies surrounding the application of Unna Boots or a multi-layer compression system. 
View Alliance Comment 
logo
Follow us on:
linkedin