Wound Care Advocacy and Policy Update from the Alliance

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The Alliance of Wound Care Stakeholders is excited to kick-off 2020 by tackling a critical issue with impact across the wound care community: what and how much clinical evidence do payers need to cover wound care products and procedures? At their April Wound Care Evidence Summit in Washington D.C., the Alliance will convene payers, policymakers, and regulators to address this question and collaboratively build solutions to common challenges.

Speakers include:

Payers – Medical Directors:

  • Aetna/US Healthcare's Dr. Raymond Fabius (retired)
  • Anthem's Dr. Alan Rosenberg (retired)
  • Humana's Dr. Charles Stemple
  • Noridian's Dr. Laurence Clark

Policy makers and regulators:

  • AHRQ's Dr. Elise Berliner
  • FDA's Dr. Cynthia Chang
  • NIH's Dr. Marcel Salive

Evidence Experts and Researchers:

  • Dr. David Armstrong, University of Southern California; Southwestern Academic Limb Salvage Alliance
  • Dr. Joseph Mills, Baylor College of Medicine; Baylor St. Luke's Medical Center Diabetic Foot and Wound Care Center
  • Dr. Vickie Driver, Brown University
  • Dr. Marissa Carter, Strategic Solutions

Advocacy Success: Alliance Advocacy Results in Significant Revision to WPS Wound Care LCD

The Alliance announces that due to the Alliance and their members' advocacy and collaborative efforts, WPS re-wrote its wound care final LCD. WPS listened to Alliance testimony and comments to significantly revise coverage policy regarding debridement coverage and dNPWT utilization parameters. The flagged issues were directly addressed in the final wound care LCD:

  • Pressure injury, stage 2 and diabetic foot ulcers are now included in the list of conditions that must be present to obtain a debridement
  • CPT codes related to debridement of other chronic non-pressure ulcers when the severity is classified as "limited to breakdown of skin" were placed back into the policy.
  • dNPWT utilization parameters that conflicted with the existing DMEMAC policy have now been removed

This late-December policy update from WPS is the result of three-year dedicated advocacy initiative. Since initial publication of this policy in 2017, the Alliance has submitted multiple comments and letters of clarifications, testified at two WPS public meetings, and engaged in numerous phone and email correspondences.

Special thanks to the American Podiatric Medical Association, the Alliance member who led the recent LCD reconsideration request that provided the opportunity for this current round of comments. Together, the APMA and the Alliance were able to coordinate the submission of 40+ comments, driving the changes seen today and demonstrating the value of collective, coordinated advocacy on behalf of the wound care community.

Long-Sought HCPCS Reforms Implemented in 2020 Coding Cycles

Together with the Alliance for HCPCS Coding Reform, the Alliance achieved a long-sought HCPCS reform advocacy "win" when CMS unveiled in December a "comprehensive strategy to foster innovation for transformative medical technologies" that included allowing medical device manufacturers to submit Healthcare Common Procedure Coding System code applications twice a year rather than once a year, and drug and biologics applications four times a year.

These process reforms are important because they can help speed the time in which new wound care products can come to market.

Q4 2019 Submitted Comments

Letter to Congress on "Cures 2.0"
The lead authors of the 21st Century Cures Act, Rep. Diana DeGette (D-CO) and Rep. Fred Upton (R-MI), solicited input from stakeholders on modernizing how new medical products are covered by public and private health insurance (an initiative dubbed "Cures 2.0"). The Alliance submitted a December letter focused on contractor coverage issues, transparency issues, and the importance of real-world evidence. Development of "Cures 2.0" will be a long process and Alliance comments put them on the record early, opening the door for continued conversations and advocacy as legislation moves forward.

USP Medicare Model Guidelines
The Alliance submitted comments in October to the United States Pharmacopeia's (USP) draft Medicare Model Guidelines. Their comments supported the creation of a new subcategory for wound care products. This would help to distinguish the chronic wound products from other subcategories, which would better protect coverage of wound care products under Medicare Part D.

Key Q4 2019 Meetings

  • SAWC Fall: Alliance executive director Marcia Nusgart, together with APMA's Dr. Jeff Lehrman, presented a session titled "How to keep on top of government regulations that might impact the treatment of your wound care patients." Overlapping with the meeting, Alliance members convened in-person for a work session focused on developing consensus comments to address the WPS draft LCD on wound care.
  • Diabetic Foot Global Conference (DFCon): Marcia Nusgart, on a panel in the role of "Regulatory Hurdler," shared perspectives at the session "Toe-ward A More Perfect Union: The State of Diabetic Foot Research in 2019."
  • Health Care Payment and Learning Action Network: Alliance staff and members participated in the Fall Summit featuring speakers from CMS, CMMI, Anthem, Humana, PCORI, National Quality Forum and more.

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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