Submitted Comments

Items Related to Prior Authorization

February 3, 2020

Comments to Texas Medicaid Draft Policy on Wound Care Management Services

In written comments, the Alliance alerted Texas Medicaid to the many provisions within its Draft Policy on Wound Care Management Services that are out of date with current standards of good wound care practice.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

August 12, 2019

Comments to CMS Patients Over Paperwork

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

Read Alliance Comment
November 21, 2017

Letter to Rep. Marsha Blackburn (R-TN) requesting exclusion of NPWT from prior authorization as part of HR 2445

The Alliance submitted a letter in support of H.R. 2445, the DMEPOS Access and Transparency Act of 2017, also known as the DATA Act of 2017. The Alliance noted concern about the impact that prior authorization for negative pressure wound therapy (NPWT) will have in a clinician’s ability to continue treatment protocols for patients while awaiting a prior authorization approval. The Alliance recommended that prior authorization should only be used when patients are not already undergoing treatment for a condition. Once treatment begins, any prior authorization requirement will impact their care. The Alliance requested that NPWT technology be carved out from the DATA Act’s prior authorization requirements in order to ensure that patients have uninterrupted access to NPWT for severe and chronic wounds and burns when Medicare local coverage criteria are met. 
View Alliance Comment
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