Submitted Comments

Items Related to MACRA

November 20, 2017

Comments to CMS “Request For Information” on the new direction of the Center for Medicaid and Medicare Innovation

The Alliance submitted comments to CMS’ request for information on new directions for the CMMI after convening many conference calls with members to determine issues of importance. Comments focused on opportunities within specialty physician models, program integrity, and benefit design/price transparency. The Alliance focused on the growing importance of real-world evidence and patient registry data. Comments spoke once again to the importance of developing quality measures that are more relevant to wound care and pointed again to the relevance of HCPCS coding reform to the CMMI’s focus on improved payment models – given the correlation of coding and payment in practice. Finally, the Alliance highlighted other models for CMMI consideration, including patient accountability models and Voluntary Quality Improvement Reporting Model for Hyperbaric Oxygen Therapy and population management models.
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August 21, 2017

Comments to CMS CY Updates to the Quality Payment Program

The Alliance submitted comments to CMS addressing the agency’s proposed updates to the Quality Payment Program (CMS-5522-P). Comments focused on the lack of relevant quality measures addressing the needs of wound care clinicians. The Alliance suggested that the creation of additional wound care quality measures is necessary to ensure continued quality care. Comments supported the use of QCDRs and the ability of all eligible clinicians to use the QCDR option for reporting.
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December 19, 2016

Comments on MACRA final rule guiding MIPS and APMs

The Alliance submitted comments to CMS on its rule: Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. Comments focused on ensuring that CMS considered of the impacts of the evolving value-based care/payment reform policies to wound care. The Alliance submitted comments to MACRA's quality physician payment proposed rule as well as on the "quality measures development plan," "patient relationships categories and codes," and "episode groups" draft policies.
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August 12, 2016

Comments on CMS Patient Relationship Categories and Codes

The Alliance submitted comments to CMS’s on its draft policy on Patient Relationship Categories and Codes. Comments noted that the proposed rule puts another burden on the clinician for tracking, coding and documentation but adds no value to patient care, or treatment outcomes. The Alliance emphasized to CMS that currently under MIPS, there are no quality measures that a wound care clinician can report for the actual wound care treatment they perform. As such, the obligatory reporting of quality, resource use, and clinical performance measures may not truly be indicative of neither the wound care work wound care practitioners do nor of the resources that they use to treat their patients. Thus, resource use for any wound care clinician will be skewed until this issue is resolved. The Alliance suggested that the Patient Relationship Categories and Codes rule be delayed at least unto 2018 or beyond to allow clinicians sufficient time to adjust to all the other MACRA and MIPS documentation and reporting changes and challenges.
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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

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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.
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September 21, 2015

Comments to DMEMACs on draft surgical dressings LCD

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