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Alliance of Wound Care Stakeholders
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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 and follow government regulations on multiple fronts and directly impact policy decisions. Recent updates include:

Comments to CY2020 Hospital Outpatient Prospective Payment System

September 27, 2019 

The Alliance submitted comments to CMS addressing relevant wound care provisions in its CY2020 Hospital Outpatient Prospective Payment System. Comments flagged concerns and provided recommendations on a range of topics including:

  • The broad sweep to move all therapeutic services from direct to general supervision

  • The implementation of prior authorization for procedures that are often utilized to treat chronic wounds that threaten both life and limb

  • Payment methodologies for CTPs

  • Lump-sum episode based payment for a wound care episode

  • The single Ambulatory Payment Classification (APC) proposal and C-APC methodologies 

  • Inaccurate APC Group assignments for CTPs due to facilities' incorrect coding/billing, which for years has resulted in APC Group assignments that fail to reflect the true costs of the CTPs.

Read Alliance Comments


Comments to CY2020 Physician Fee Schedule

September 27, 2019

The Alliance submitted detailed comments to CMS on a range of provisions in the proposed Physician Fee Schedule that impact wound care providers. Comments focused on:

  • Evaluation and Management Codes

  • The conclusions of three RAND Corporation reports utilized in the report to support certain provisions (CMS had contracted RAND to collect data on the number and level of post-operative visits for surgical global codes provided to Medicare beneficiaries)

  • Relative Value Units (RVUs) for Physical Therapy

  • Practice Expense (PE) RVUs for Disposable Negative Pressure Wound Therapy (CPT Codes 97607 & 97608)

  • Open Wound Debridement (CPT Codes 97597 and 97598)

  • Ultrasonic Wound Assessment (CPT Code 97610)

  • The process of removing measures from the MIPs for being “topped out”

Read Alliance Comments


Comments to CMS CY2020 Home Health Prospective Payment System

September 9, 2019

The Alliance submitted comments to CMS in response to the proposed updates in the CY 2020 Home Health Prospective Payment System. The Alliance noted concern with CMS’ proposal to reduce the Requests for Anticipated Payment (RAP), asking that CMS consider the cash flow requirements of new home health agencies who also have capitalization needs and smaller agencies and those in rural areas have a significant need for cash flow support. The Alliance also strongly opposed the removal of pain measures from the Home Health Quality Reporting Program (HH QRP) and the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS surveys). While CMS reports that elimination of the measure is in line with the agency’s broader efforts to address the opioid epidemic, the Alliance flagged that pain remains an issue that is important to patients served in the home health setting  and there is no evidence to suggest that the use of these measure is linked to opioid misuse.

Read Alliance Comments


Comments to CMS Patients Over Paperwork

August 12, 2019

The Alliance submitted comments to CMS in response to its Request for Information regarding Patients Over Paperwork related to reporting and documentation requirements, coding and documentation requirements for Medicare or Medicaid payments, and prior authorization procedures. Our comments focused on several key issues, including:

  • NCCI edits

  • HCPCS coding reform

  • Local coverage decisions (LCDs) versus coverage articles (LCAs)

  • Prior authorization

  • Billing for disposable negative pressure wound therapy in home health care setting

  • Implementation timing of rules issued by CMS

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