Alliance Urges CMS to Address Front-Line Wound Care Practitioners’ Challenges

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Early in the pandemic, the Alliance’s rapid response team developed a position statement calling for the protection of wound care as an essential service. That March statement was just the first step of their advocacy. Since that time, they’ve issued to HHS and CMS a series of letters and emails and participated in many calls to protect wound care. In their April letter to HHS/CMS, they detailed specific policies that, with regulatory relief, could remove barriers to treat wound care patients efficiently and effectively during the pandemic. While many of the Alliance’s recommendations were incorporated, many key ones were not – and they’ve been requesting and refining them in May recommendations and July requests to CMS's interim final rules to ensure that the Agency updates provisions impacting wound care based on Alliance members’ front-line experience.

In direct response to issues reported by members, the Alliance has made a series of specific recommendation to CMS in comments, calls and conversations. These include:

  • Exapnsion of reimbursement for wound care-related telehealth visits
  • Waive standard written order provisions in select LCDs
  • Allow dNPWT telehealth billing
  • Permit total contact casting to be provided on the same date of service as other procedures
  • Increase access and reimbursement for alternative methods of debridement
  • Modify documentation requirements for continued need and refill of surgical dressings and other supplies
  • Delay moving forward with the competitive bidding program during the public health emergency
  • Enable patients to be treated at all appropriate sites of care outside traditional office and hospitals settings

The coronavirus has drastically changed how and where wound care providers treat their patients. CMS’s rules, waivers and policies must evolve to reflect this new world. COVID-19

COVID-19 Advocacy Leadership: Q2 Comments & Meeting:

Pursuing Regulatory Relief Waivers for Wound Care: CMS Letter
The Alliance sent a letter to HHS/CMS requesting temporary regulatory waivers to remove barriers and give flexibility to wound care clinicians amid the evolving realities of the pandemic. The Alliance identified specific provisions related to site of service, reimbursement, documentation, DME access and other relevant issues. (April)

Removing Barriers to Care: Comments to PHE 1st Interim Final Rule
In comments to CMS's Public Health Emergency (PHE) Interim Final Rule, the Alliance supported the Agency’s implementation of many policy modifications they’d requested in their April letter and pursued action on issues they’d flagged that had not been addressed, including: surgical dressing and negative pressure wound therapy billing, CTP co-pays, reimbursement for alternative methods of debridement, documentation requirements and more. (May)

Addressing Clinical Challenges: Comments to PHE 2nd Interim Final Rule
To ensure that policy updates reflected the realities of challenges faced by front-line wound care clinicians, the Alliance called on CMS to expand reimbursement for wound-care related telehealth visits; provide flexibility in documentation requirements for refill of surgical dressings and other supplies; and permit medically necessary procedures to take place on the same date of service. Comments also addressed competitive bidding, appropriate use criteria, temporary relocation sites, and LCD/DME issues. (July)

Representing Wound Care on CMS Stakeholder Calls

  • Alliance staff have regularly participated on CMS’s weekly “Office Hours” calls so that they can determine whether their issues are being addressed, plan their next advocacy actions and communicate the most up-to-date information to membership. The Alliance has flagged relevant calls and reported to members when relevant issues were raised or updated.
  • In April, Alliance staff and representatives from clinical and business entity members participated in a call with CMS Centers for Medicare Management to address issues in the surgical dressing LCD.

Educating members about the intricacies of policy changes:

  • Launched the COVID-19 Action Center on the Alliance website to serve as a go-to resource page for all wound care related COVID-19 updates. (March)
  • Collaborated in two webinars: “Understanding HIPAA During COVID-19” with AAWC and “Wound Care Challenges and Solutions During the COVID-19 Pandemic: A Roundtable Discussion with Frontline Experts” with WoundSource. (May)
  • Co-authored “Wound Center Without Walls: The New Model of Providing Care During the COVID-19 Pandemic” published in WOUNDS and spearheaded by Alliance member Dr. Lee Rogers. (June)

General (Non-COVID) Advocacy Leadership: Q2 Comments & Meeting:

Expanding CTP/dNPWT Payment Policies: Letter to MACs
The Alliance submitted a June letter to three Medicare Administrative Contractors (MACs) – Palmetto, National Government Services (NGS) and Wisconsin Physician Services (WPS) – requesting payment for the application of cellular and/or tissue products for skin wounds (CTPs) and disposable negative pressure wound therapy (dNPWT) services – when taking in place in the home, assisted-living facilities and nursing facilities.

  • UPDATE: Palmetto stated it will pay for disposable negative pressure therapy in nursing facilities at the applicable Medicare physician non-facility rate. The Alliance will continue to seek payment for services provided in the home and assisted living facilities, as well as pursue similar updates from the other two MACs.

Requested Reconsideration of Surgical Dressing LCD
The Alliance submitted a formal reconsideration request for the Surgical Dressing LCD (L33831) to the DMEMAC medical directors. The Alliance is seeking an update in the category “Alginate and/or other Fiber Gelling Dressings” to allow these to be used as both primary and secondary dressings. Currently they can only be billed as primary dressings.

Serving as a Go-To Resource for the GAO on Wound Care & CTPs
The Government Accountability Office reached out to the Alliance earlier this year (Feb.) for insights when it was tasked to develop two reports: “How Medicare Provides its Beneficiaries Treatment for Severe Wounds” and “The Impact of Medicare’s Policy for Packaging High-cost Drugs and Biologicals.” The Alliance provided additional expertise to the GAO in June when it reached out for insights as it analyzed Medicare’s claims data to learn more about the high cost of drugs, including CTPs.

Representing Wound Care Concerns to Noridian’s CAC
The Alliance served as a resource to Noridian and participated in its April Contractor Advisory Committee (CAC) call on both wound care and CTPs. The Alliance expressed concern that the MAC’s call did not focus on a discussion of evidence, which is generally agreed to be the purpose of a CAC meeting. The Alliance will follow up with Noridian as the MAC develops
its draft LCDs later in 2020.

Be Up To Speed: Recent Policy Updates Relevant to Wound Care

  • JUST RELEASED: Hospital Outpatient PPS and Physician Fee Schedule: The CY2021 Medicare Outpatient Prospective Payment System (OPPS) Proposed Rule and the CY2021 Medicare Physician Fee Schedule Proposed Rule recently published. The Alliance circulated a summary to membership and will be convening calls to discuss issues to be addressed in submitted comments. (August)
  • CMS will be convening a virtual meeting of its Advisory Panel on Hospital Outpatient Payment on Aug. 31.
  • AHRQ: The Agency for Healthcare Research and Quality's Technology Assessment Program posted a draft systematic review for comment: "Platelet-Rich Plasma for Wound Care in the Medicare Population." (June)
  • CMS Office of Burden Reduction: CMS announced the creation of the Office of Burden Reduction & Health Informatics to unify the agency’s efforts to reduce regulatory and administrative burden and to further the goal of putting patients first. The new office is an outgrowth of the agency’s Patients over Paperwork Initiative. (June)
  • HCPCS Codes: CMS released 13 new CTP HCPCS codes in MLN Matters MM11814, which became effective on July 1, 2020. There was one code of particular interest: C1849-skin substitute, synthetic which was designated in the high cost bucket where the rest are in the low bucket.
  • COVID-19 Action & Resource Center: Check the page for policy updates such as the:
    • New COVID-19 FAQ on Medicare Fee-for-Service Billing
    • Expansion of the Hospital Without Walls initiative
    • New MLN Matters Medicare Fee-For-Service (FFS) Response to the Public Health Emergency
    • Recordings/transcripts of CMS COVID-19 stakeholder calls.

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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