In their quarterly Alliance Advocacy Update, the Alliance of Wound Care Stakeholders (Alliance) updates health care professionals on the Centers for Medicare & Medicaid Services proposed fee schedules, recent meetings and conferences, and the latest publications and policies relevant to wound care.
CMS "Comment Season" Heats Up
"Comment season" is heating up. As summer temperatures rise, the Alliance of Wound Care Stakeholders (Alliance) is busy reviewing and addressing the fiscal year 2019 (FY2019) prospective payment system updates from the Centers for Medicare & Medicaid Services (CMS) that can have impacts large and small across the wound care space.
Earlier this summer, CMS issued the proposed rules for the hospital inpatient prospective payment system (PPS), the skilled nursing facilities (SNFs) PPS, and the interim final rule for the durable medical equipment (DME) fee schedule adjustments (which also address competitive bidding) as part of the End-Stage Renal Disease(ESRD) DME proposed rule.
And just this past week, CMS put out the proposed 2019 physician fee schedule, which the Alliance will be reviewing and circulating additional information about to aid in their preparation of comments.
Still to come is the hospital outpatient PPS, which the Alliance will review with an eye to impacts in the wound care space.
Be sure to review the "Recent Publications" section below for links and brief overviews.
Below is a summary to keep you up to speed on the Alliance’s comments submitted, comments in process, and comments to be developed and circulated for review over the weeks ahead. The Alliance would like to thank you in advance for your input and valuable feedback as comments are developed. And importantly, enjoy these dog days of summer, whether you are at your desk or at the beach or following your bliss to an exotic port of call.
Q2 Submitted Comments: Ensuring Alliance's Clinical Expert Perspective Is Heard
CMS Hospital Inpatient PPS
The Alliance submitted comments to CMS' "Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Fiscal Year 2019 Rates" supporting efforts to "streamline and de-duplicate measures." We noted some specific concerns and recommendations regarding measures surrounding pressure ulcers. The Alliance recommends that CMS:
- Remove pressure ulcers (PSI 03) from the NQF #5031 Patient Safety and Adverse Events Composite Measure.
- Create a stand-alone quality measure for PSI 03, Pressure Ulcer Rates.
- Or, as an alternative, increase the weight currently outlined in the proposed rule for pressure ulcers.
- Implement the Equal Measure Weights approach outlined in the proposed rule.
WPS Wound Care LCD
The 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—and requested clarity on 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); utilization parameters for dressing changes, and other issues of concern.
"While we appreciate that WPS did adopt several of our previous recommendations, the Alliance still has significant concerns with some of the language contained in the final LCD - including many clinically incorrect statements...We are reaching out to WPS in order to obtain clarification...so that we can provide clarity to our members."
Key Q2 Meetings and In-Person Advocacy
Alliance Q2 meetings with stakeholders included:
Recent Publications and Policies Relevant to Alliance
- Physician fee schedule: On July 12, CMS released the proposed 2019 updates to its physician fee schedule. The policy proposes a number of coding and payment changes to reduce administrative burden and improve payment accuracy for E/M visits. The policy includes a proposed new single blended payment rates for new and established patients for office/outpatient E/M level 2 through 5 visits and a series of add-on codes to reflect resources involved in furnishing primary care and non-procedural specialty generally recognized services. Similarly, the proposed rule solicits comment on how documentation guidelines for medical decision-making might be changed in subsequent years. The Alliance will be reaching out to membership as specific impact to wound care providers are assessed and comments are prepared.
- DMEPOS payment policy: CMS released on July 11 proposed changes to DMEPOS payment policy, particularly to address the likelihood that current competitive bidding contracts will expire before CMS can recompete/award new contracts. CMS is also looking at ways to revise the gap-filling process. This rule also includes proposals that address Medicare fee schedule payments for DME furnished on or after January 1, 2019 in areas of the country where competitive bidding is not in effect. The proposed rule also solicits stakeholder feedback on CMS' approach to establishing the fee schedule amounts for new DME technologies. See the full text of the rule and the accompanying fact sheet. The Alliance will be reaching out as they develop comments.
- Skilled nursing facilities PPS: In May, CMS released the update to the payment rates used under the PPS for SNFs for FY2019.
- ESRD DME proposed rule: Within this proposed rule published in May, CMS also addresses DME, Prosthetics, Orthotics, and Supplies (DMEPOS) and competitive bidding. CMS temporarily increases the fee schedule rates from June 1, 2018, through December 31, 2018, for certain DME items and services and enteral nutrition furnished in rural and non-contiguous areas (Alaska, Hawaii, and U.S. territories) of the country not subject to the DMEPOS Competitive Bidding Program.
- Home health demonstration project: In May, CMS published for comment "Pre-Claim Review Demonstration for Home Health Services" to "help assist in developing improved procedures for the identification, investigation, and prosecution of potential Medicare fraud." This update includes many elements of concern to wound care and to the Alliance. The Alliance will be developing comments (due by July 30). CMS also published an accompanying Frequently Asked Questions document on the demonstration project.
- GAO Report: The Alliance flagged, shared, and discussed with membership the April GAO report "CMS Should Take Actions to Continue Prior Authorization Efforts to Reduce Spending" and accompanying summary sheet.
- Pneumatic compression device policy article: The Alliance alerted membership to the April policy article and flagged concerns on certain LCD landing pages that "At this time 21st Century Cures Act applies to new and revised LCDs that restrict coverage, which require comment and notice. This revision is to an article that is not a local coverage determination..."
- MEDPAC report: MEDPAC issued a June report and, as expected, there was a chapter devoted to medical devices in which competitive bidding is addressed. MEDPAC does state that more products could be added to competitive bidding (see chapter 6).
- Lymphedema Treatment Act: Flagged to membership, the Act (H.R. 930), was introduced in the House, to provide for Medicare coverage of certain lymphedema compression treatment items as items of DME. The Alliance will be submitting a letter of support to submit to House and Senate leadership.
- Stark Law Reform: In July, CMS published a request for information (RFI) to seek input from the public on how to address any undue regulatory impact and burden of the physician self-referral law. The RFI outlines 20 specific categories/questions for input.
Check out the Alliance of Wound Care Stakeholders’ new website, www.woundcarestakeholders.org, which makes it easy to keep track of the Alliance’s advocacy on coding, coverage, and reimbursement issues to better serve and protect patients and providers.
About the Alliance of Wound Care Stakeholders
The Alliance of Wound Care Stakeholders: The Alliance is a nonprofit multidisciplinary trade association of health care professional and patient organizations whose mission is to promote quality care and access to products and services for people with wounds through effective advocacy and educational outreach in the regulatory, legislative, and public arenas.
The views and opinions expressed in this blog are solely those of the author, and do not represent the views of WoundSource, Kestrel Health Information, Inc., its affiliates, or subsidiary companies.