Submitted Comments

In written comments, the Alliance alerted Texas Medicare to the many provisions within its Draft Policy on Wound Care Management Services that are out of date with current standards of good wound care practice. Comments addressed policy provisions surrounding CTPs, negative pressure wound therapy (NPWT and dNPWT), surgical dressings, debridement, documentation, prior authorization and more, and included specific recommendations to update the policy as it moves from draft to final. 
Read Alliance Comments

The Alliance submitted comments to CMS in response to its Request for Information regarding Patients Over Paperwork related to reporting and documentation requirements, coding and documentation requirements for Medicare or Medicaid payments, and prior authorization procedures. Our comments focused on several key issues, including:

• NCCI edits
• HCPCS coding reform
• Local coverage decisions (LCDs) versus coverage articles (LCAs)
• Prior authorization
• Billing for disposable negative pressure wound therapy in home health care setting
• Implementation timing of rules issued by CMS