Alliance Update: Wound Care Policy News and Comments for Q2 2018 Protection Status
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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 that we can provide clarity to our members."

Key Q2 Meetings and In-Person Advocacy

Alliance Q2 meetings with stakeholders included:

  • Pricing Data Analysis and Coding (PDAC) surgical dressing meeting: On April 12, the Alliance, in tandem with the Coalition of Wound Care Manufacturers, convened more than 50 PDAC nursing staff and DME Medicare Administrative Contractor (DMEMACS ) medical directors at Noridian's offices in Fargo, ND for a full-day educational session that focused on wound care and wound healing topics. The meeting was unique in that the speakers also addressed each surgical dressing category and then circulated the different dressings so that each attendee could see the different sizes, shapes, etc. to better understand their uses and technology. The Alliance was invited to lead this session because of their reputation over the years with the PDAC and DMEMACs of being the "go-to" expert in providing objective comprehensive wound care information. This shows that over the long term, persistent advocacy has helped the Alliance achieve a reputation as credible respected partners (see article from our Q1 newsletter for more information).
  • HCPCS public meetings: The Alliance participated in the May 16 HCPCS public meeting addressing Drugs and Biologicals which included cellular and/or tissue-based products for skin wounds (CTPs) and the June 6 HCPCS public meetings addressing DME and Accessories/Orthotics and Prosthetics/Supplies/Other (which included discussion of wound closure devices and dressings).
  • ASTM: Alliance membership participated in a May ASTM workgroup conference call in which a new proposal for CTP nomenclature was being discussed for vote. The Alliance believes the new proposal contains inaccurate clinical and scientific information. They again ask those Alliance members who either use or manufacture CTPs to become ASTM members to have the opportunity to vote on these important issues that impact this wound care segment.
  • Palmetto "Ask the Contractor" Teleconference: The Alliance participated by phone in the May teleconference, which focused on HBOT and flagged the opportunity to their members. Palmetto clinical consultants provided information concerning Medical Review Targeted probe, findings for HBOT, and how to improve documentation. The Alliance flagged inaccuracies in the discussion and is now awaiting Palmetto's release of the transcript. They may submit additional comments following issuance of the transcript.
  • EWMA presentation: Alliance Executive Director Marcia Nusgart presented the findings of "An Economic Evaluation of the Impact, Cost and Medicare Policy Implications of Chronic Nonhealing Wounds" at the May European Wound Management Association (EWMA) meeting in Krakow, Poland. The findings were very well received, and meeting participants were eager to obtain copies of the full study, available on the Alliance website.
  • Member conferences: Spring conferences of interest to Alliance members included:

    • Health Datapalooza - April/Washington, DC
    • International Society for Pharmacoeconomics and Outcomes Research (ISPOR) - May/Baltimore
    • WOCN Society Annual Conference - June/Baltimore (Marcia Nusgart attended and met with WOCN staff and leadership)
    • Society for Vascular Medicine - June/Chicago
    • American Diabetes Association - June/Orlando
    • American Association of Nurse Practitioners National Conference - June/Denver
    • American Physical Therapy Association - June/Orlando
    • Undersea & Hyperbaric Medical Society - June/Orlando (Marcia Nusgart attended and met with UHMS staff and leadership)

  • CMS open door forum: The Alliance alerted membership to CMS' June 12 "open door forum" on Templates and Clinical Data Elements (CDEs) for Therapeutic Shoes for Persons with Diabetes.
  • Spring SAWC: The Alliance convened an in-person meeting in April at the Spring SAWC in Charlotte, featuring guest speakers Stella R. Mandl, Deputy Director Division of Chronic and Post-Acute Care; and Joseph B. Clift, Health Insurance Specialist, who addressed "How the 'Impact Act' Impacts the Alliance of Wound Care Stakeholders." Also at SAWC, the Alliance convened their CTP and NPWT workgroups and had a poster focused on the economic impact of chronic wounds, gleaned from their research published in Value in Health.
  • UPCOMING: Fall SAWC - Join the Alliance at their in-person meeting at the Fall SAWC in November in Las Vegas. The specific date and time will be shared shortly.

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.

Other Updates

Check out the Alliance of Wound Care Stakeholders’ new website,, 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.

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