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 3, 2026
Cosigned Letter to Dept. of Education Proposed Rule
Together with more than 270 nursing and aligned health care organizations, the Alliance cosigned a letter to the U.S. Department of Education urging the inclusion of post-baccalaureate nursing degrees (MSN, DNP, Ph.D.) to the list of “professional” degrees as outlined in the Agency’s recent notice of proposed rulemaking on Reimagining and Improving Student Education (RISE). “There are criteria the Department established, based on the longstanding definition incorporated by Congress, and post-baccalaureate nursing programs meet all of them… We stand united in our request that the Department include postbaccalaureate nursing degrees explicitly in the list of ‘professional’ degrees. This is consistent with regulatory language and will help ensure a stable pathway of essential nursing professionals for years to come,” the letter states. RISE puts in place adjustments to federal student loan borrowing limits and repayment plans, impacting access to federal student loans for individuals pursuing higher degrees in a number of fields.

February 27, 2026
Letter to Acumen & Non-Pressure Ulcers Episode-Based Cost Measure Workgroup
In a letter submitted to Acumen’s MACRA Cost Measures Support Team and its Non-Pressure Ulcers Episode-Based Cost Measure Clinician Expert Workgroup, the Alliance provided feedback on the groups’ revised non-pressure ulcers episode-based cost measure. The measure is in the process of being refined following the Alliance’s previous advocacy outreach flagging significant methodology flaws and inaccuracies. The Alliance recorded its support for several of the updates but also submitted a number of clarity-seeking questions and voiced ongoing concerns with the measure’s cost allocation and claim attribution data — both of which are essential to an accurate and effective measure.

February 6, 2026
Letter Requesting Blood-derived Products HCPCS Code G0465 be Increased under CMS “Potentially Misvalued Code” Process
The work relative value units (“RVUs”) assigned for HCPCS code G0465 do not accurately reflect the time, intensity, mental effort and judgment, technical skill and physical effort associated with the delivery of autologous platelet rich plasma (“PRP”) or other blood-derived products for the treatment of chronic, non-healing diabetic wounds, the Alliance told CMS in a letter requesting that the code be considered – and the work RVUs updated – under the “Potentially Misvalued Code” process. The Alliance also asked CMS to clarify its billing and reimbursement policies for multiple applications of an autologous blood-derived product when used to treat a large surface area wound and/or to treat multiple wounds on the same date of service. “Multiple product kits may be needed… [and] requiring that an additional application of autologous blood-derived product be subject to a 50 percent reduction in reimbursement for the code means that the cost of the product is not covered. Accordingly, clinicians are not able to furnish multiple applications of autologous blood-derived product on the same date of service in the physician office setting, even when it is medically necessary and appropriate to do so.” The end result: “Patients with multiple wounds or wounds with large surface areas either need to be treated on separate days or in the hospital outpatient setting, which creates a disparity in access and leads to increased Medicare costs for patients who could have otherwise been treated safely and effectively in the physician office setting on the same day,” the Alliance wrote.

• blood-derived products

January 30, 2026
Comments on Proposed Changes to CMS Medicare Advantage Program
The Alliance submitted its wound care perspective to CMS’ Proposed Policy and Technical Changes to the Medicare Advantage Program for Contract Year 2027. The Alliance raised concerns regarding how modifications to the Hierarchical Condition Category risk adjustment model could impact on beneficiaries requiring wound care services. Comments also flagged that Medicare Advantage (MA) enrollees with lymphedema are not consistently receiving the coverage to which they are entitled, despite statutory requirements mandating that MA plans provide benefits that are at minimum equivalent to those available under traditional Fee-for-Service Medicare. “Analysis of coverage policies, beneficiary reports, and plan documents across multiple MA plans demonstrates that coverage for lymphedema compression treatment items varies dramatically from plan to plan…Some MA plans have implemented coverage policies that closely mirror FFS Medicare standards, while others have erected substantial barriers that effectively limit beneficiary access to appropriate lymphedema management supplies,” the Alliance reported, urging updates.