Alliance of Wound Care Stakeholders

In addition to the efforts taken on by the Society we have also enjoyed success through our membership in the Alliance of Wound Care Stakeholders (The Alliance). The Alliance of Wound Care Stakeholders is a nonprofit multidisciplinary trade association of physician medical specialty societies and clinical associations 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. Through the Alliance WOCN is able to comment, follow government regulations on multiple fronts, and directly affect policy decisions. Recent comments/letters include:

September 15, 2025

• Comments to Proposed 2026 Hospital Outpatient Prospective Payment System (OPPS) Update

The Alliance submitted comprehensive comments to CMS’ proposed CY 2026 Hospital Outpatient Prospective Payment System (CMS-1834-P) focused on a range of provisions impacting wound care, including:

• CTPs: The Alliance commended CMS efforts to improve program integrity in the reimbursement of CTPs. The Alliance has advocated over the years for CMS to fix flaws and inadequacies in the OPPS bundled payment methodology and applauds the Agency’s current efforts to do so. The Alliance supports CMS’ proposal to pay for CTPs separately, as unbundling will finally enable hospital outpatient departments to be reimbursed for CTP products for larger wounds as well as receive equalized payment for the application of CTPs regardless of a wound’s anatomic location – fixes that the Alliance has elevated to CMS for years. Comments addressed details of CMS’s proposed “incident to supplies” payment methodology and the creation of new reimbursement categories for CTPs based on FDA regulatory categories versus a single payment approach.

September 12, 2025

• Comments to Proposed 2026 Medicare Physician Fee Schedule (PFS) Update

The Alliance submitted comprehensive comments to CMS’ proposed CY 2026 Medicare Physician Fee Schedule (CMS-1832-P) focused on a range of provisions impacting wound care. The Alliance agreed with CMS that the current utilization and reimbursement for CTPs (skin substitutes) in the physician office setting has led to a significant and unsustainable growth in spending and there is a need to “limit some of the current profiteering practices occurring.” The Alliance applauded CMS for addressing this issue that has been plaguing the industry for several years. The current methodology has created perverse incentives that resulted in explosive growth in spending, with little to no correlation to improved outcomes. While the Alliance does not agree that CTPs are “supplies,” we do support CMS’ proposal to pay for CTPs separately as “incident-to-supplies” without bundling or packaging, creating site neutral payment under both the PFS and OPPS. “Separate payment appropriately recognizes these products’ distinct value in improving outcomes for patients, enhances access, and promotes clinically appropriate site-of-service decisions,” the Alliance wrote. Comments requested an increase to the proposed 2026 payment rate and provided inputs on the new payment methodology and proposed creation of reimbursement levels for CTPs based on FDA regulatory categories.

Alliance comments to the Physician Fee Schedule also recommended:

• Efficiency Adjustment withdrawal
• Blood and Blood Derived Products payment adjustment
• Hyperbaric Oxygen Therapy coding methodology
• Point of Care Imaging (POCI) reimbursement under Software as a Service (SaaS) frameworks
• Therapeutic Shoes for Diabetic Patients access improvements

August 27, 2025

• Comments to Proposed 2026 Home Health Prospective Payment System Update

The Alliance submitted comments to CMS’s proposed CY 2026 Home Health Prospective Payment System Rate Update, with a focus on provisions related to home health payment reductions, face-to-face supervision changes, lymphedema compression coding and payment, and issues related to the proposed reintroduction of the Competitive Bidding Program.

July 22, 2025

• Letter Supporting State Legislation to Modernize Podiatric Scope of Practice Law & Expand Access to Care

The Alliance submitted a letter of support for Massachusetts State House Bill 2407 / Senate Bill 1542, “An Act Relative to the Definition of Podiatry,” that would update and modernize the podiatric scope of practice law in Massachusetts to allow podiatrists to treat the foot, ankle, and lower leg.

July 14, 2025

• Recommendations on Deregulation Opportunities Submitted to HHS

HHS issued a Request for Information in May soliciting recommendations on specific regulations that should be eliminated “to lower healthcare costs, reduce burdens on physicians, and address the prevalence of chronic disease.” The Alliance engaged its multiple workgroups to identify specific areas for inclusion and submitted to HHS a detailed chart of regulations with corresponding recommendations across specific guidance. These included recommendations to:

• Correct several problematic NCCI edits including Total Contact Cast (TCC)
• Revise Coverage w Evidence Development (CED) processes and the Transitional Coverage for Emerging Technologies (TCET) pathways – as they are cumbersome and do not achieve the desired results of bringing product to market faster.
• Remove burdens to the Medicare process for obtaining therapeutic shoes for patients with diabetes that currently creates unnecessary delays in care.
• Issue clear, enforceable guidance to Medicare Advantage Programs requiring that their coverage and documentation requirements align with, and are no more restrictive than, those established under Medicare Fee-for-Service (FFS) as is required in regulation.
• Update provisions for lymphedema compression treatment coverage to enable payment for clinicians to measure and fit lymphedema compression garments, and more…