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:
March 17, 2025
The Alliance submitted comments to CMS’ Proposed Guidance Document: Study Protocols That Use Real-world Data (RWD) urging that use of RWD for real-world evidence (RWE) be extended to all coverage determinations, not just to the national coverage determination (NCD) coverage with evidence development (CED) process as proposed. “Using RWE only for NCDs with CED is rather limiting as there are very few NCDs based on CED. If the Agency is permitting RWE to be used for coverage purposes, the use should be extended to all coverage determinations,” the Alliance advocated to CMS, submitting the recommendation that “any coverage policy should consider RWE as an adjunct to Level 1/Level 2 evidence when determining product coverage since it aligns with the Congressional intent of the 21st Century Cures Act in 2016 encouraging the use and acceptance of RWE. Therefore any guidance offered in terms of appropriate evidentiary standards including the use of RWE should apply not only to NCDs based on CED or NCDs in general but also to Local Coverage Determinations (LCDs).”
- real-world evidence
- real-world data
- Comments to CMS Proposed Guidance on Study Protocols That Use Real-World Data
March 10, 2025
The Alliance signed on to a letter with the American Diabetes Association, American College of Cardiology, Society for Cardiovascular Angiography & Interventions and others, requesting that CMS create a national coverage determination (NCD) for peripheral artery disease (PAD) screening and recommended follow-up testing for at-risk Medicare beneficiaries as part of efforts to identify, prevent, and mitigate diabetes-related complications and amputations.
February 28, 2025
The Alliance joined with 100+ healthcare provider organizations urging Congress to take immediate action to reverse the current 2.8% Medicare Physician Fee Schedule Conversion Factor (CF) reduction now in effect and provide clinicians with a positive payment update in the upcoming March 2025 appropriations bill. “The ongoing downward reimbursement spiral is contributing to consolidation in the health care system as more clinicians are no longer able to sustain their practices,” the coalition of provider groups told Congress, advocating for inclusion of the bipartisan Medicare Patient Access and Practice Stabilization Act (H.R. 879) in the March package. H.R. 879 is designed to safeguard the financial stability of physician practices with provisions that protect clinicians from the 2.8% Medicare payment cut and a 2% inflation update to help offset rising costs and strengthen the sustainability of practices across the country.