The Alliance of Wound Care Stakeholders' quarterly update on their ongoing advocacy initiatives to includes an overview of their comments on wound care policies, upcoming meeting dates and a list of recent publications.
CMS, Commercial Payers and Capitol Hill
Each year, the Centers for Medicare and Medicaid Services' (CMS) proposed annual updates to the Physician Fee Schedule and Hospital Outpatient Prospective Payment System (HOPPS) demand significant time and resources to understand the specific impacts to wound care providers and patients. This year, the Alliance’s comments served as a call to arms to wound care professionals. For example:
- Following a series of calls and discussions, the Alliance submitted aligned comments that outlined specific unintended consequences of the proposed payment methodologies related to the packaging of cellular and tissue based products for skin wounds (CTPs) in the HOPPS and provided detailed alternative solutions.
- They voiced opposition to the Physician Fee Schedule's proposed consolidation of Evaluation and Management codes and the corresponding reduction in payment for Evaluation and Management (E/M) services for those that provide the most complex care. Specifically, they opposed the "singling out" of podiatric physicians in the Schedule's proposed creation of separate E/M codes and reimbursement for these specialists. They convened a work group and brought in a former commercial payer medical director after United Healthcare issued a policy that removed coverage for most CTPs. They have sent a letter and meeting request to UHC.
- to the Alliance submitted a letter of support to Capital Hill for the Lymphedema Treatment Act (S. 498, H.R. 930), which would grant CMS the statutory authority to cover compression bandages for lymphedema under the Medicare benefit.
The Alliance intends to focus future attention on Capitol Hill on the issue of LCD transparency.
On Sept.23, the U.S. House of Representatives passed the Local Coverage Determination Clarification Act (H.R. 3635). The Act revises the process by which Medicare Administrative Contractors (MACs) issue and reconsider local coverage determinations (LCDs). While the Alliances supports this legislation, they believe it could do more and are exploring an advocacy path forward for policy articles to also be included. MACs are more liberally using policy articles, which don't require the notice-and-comment procedure of LCDs. Many of these policy articles are providing much more than clarification, they are oftentimes setting new policy.
While the legislation likely won't be moved to the Senate this year, the Alliance is hopeful the legislation can have a path forward in 2019.
Key Q3 Meetings & In-Person Advocacy
- Health Care Payment Learning & Action Nework Summit: The Alliance attended and alerted membership to this Oct. 22 LAN meeting in Northern Virginia as an opportunity to network with CMS and private payer staff while focusing on "Partnering for the Future" to improve patient outcomes and bend the cost curve.
- Physician Fee Schedule call: Alliance leadership participated on a July 12 conference call with CMS Administrator Seema Verma and her staff as they summarized the Physician Fee Schedule proposed rule relating to documentation requirements and payment for E/M visits and advancing virtual care. A copy of the CMS presentation was circulated to membership.
- OPPS Advisory Panel Meeting: The Alliance alerted membership to, attended and spoke at the Aug. 20 meeting of CMS' Advisory Panel on Hospital Outpatient Payment, an expert outside advisory panel that provides to CMS technical advice regarding the clinical integrity of the Ambulatory Payment Classification (APC) groups, relative payment weights, and supervision levels.
- CMS Home Health Open Door Forum: The Alliance alerted members to the July CMS forum featuring Hillary Loeffler, Director, Division of Home Health & Hospice at CMS.
- Member conferences:
- APWCA: Alliance leadership attended and spoke at the APWCA meeting September 6-8 in Baltimore.
- APMA: Alliance leadership attended the July APMA annual meeting and had a "guest speaker" slot at the APMA booth to speak about the Value in Health study.
- Amputee Coalition: hosted its annual meeting July 12-14 in Tucson.
- Fall SAWC: The Alliance held an in-person meeting at the Fall SAWC on November 2nd.
Recent Publications & Policies Relevant to Alliance
- CMS Inpatient PPS Final Rule issued in August. The Alliance circulated a summary comparing their submitted comments to the final rule.
- APMA issue brief: The Alliance circulated an American Podiatric Medical Association "issue brief" on how the proposed Physician Fee Schedule specifically impacts podiatrists. They make many points relevant to wound care.
- DMEPOS Competitive Bidding: CMS published in July its End-Stage Renal Disease Prospective Payment System, which also covers the competitive bidding program for DMEPOS. The proposed rule was circulated to Alliance members.
- MLN Matters article published in August on Recent and Upcoming Improvements In Hospice Billing and Claims Processing
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.