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 23, 2023
Alliance Statement to House Appropriations Subcommittee public witness hearing
The Alliance submitted a statement to the House Appropriations Subcommittee on Labor, Health and Human Services, Education and Related Agencies public hearing (March 18) to be on the record regarding our concern about the approach CMS is taking with respect to proposed payment changes to skin substitutes (CTPs) in the Medicare Physician Fee Schedule that we believe will negatively impact patient access to care. The Alliance requested that Congress include language in the CMS Program Management Account appropriations bill to ensure that CMS adheres to the recommendations put forward in the March 2023 Office of Inspector General’s report on Average Sales Price (ASP) for Skin Substitutes in order to maintain access to these products while saving valuable dollars to the Medicare Trust Fund.

March 6, 2023
Comments to Medicare Prior Authorization Processes
The Alliance submitted comments to CMS proposed rule on Advancing Interoperability and Improving Prior Authorization (PA) Processes for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies. While the Alliance is supportive of the Agency’s proposal to streamline PA process, we expressed concern about the lack of provisions addressing payer accountability. “Payers need to be held accountable or the changes proposed will have little effect,” the Alliance wrote. For example, in the proposal, CMS states that if a provider does not hear back from the payer in the timeframe proposed then the provider “should contact the payer.” This certainly does not streamline the burden on providers, the Alliance noted, and does not hold payers accountable for their lack of response. The Alliance encouraged CMS to include payer accountability provisions as this proposal moves towards finalization.

February 10, 2023
Comments to CMS Skin Substitute Town Hall
The Alliance submitted comments to the director and deputy director of CMS’ Hospital and Ambulatory Policy Group to augment oral comments shared at the Agency’s January 2023 Skin Substitute Town Hall. “Any efforts by the Agency that will curtail access to CTPs will have a direct impact on infection and amputation rates,” wrote the Alliance, noting that CMS “has failed to provide any assessment of this impact or details about its rationale for the change such as: an impact analysis, details on how CMS will implement bundling in the physician office setting, the criteria used for setting the rates, or the reasons for making this seismic change. Moreover, the Agency has not demonstrated that the bundling of these products will not impact access to these products, especially to our greatly underserved Medicare patient populations who suffer disproportionately.” The Alliance included a list of detailed questions for the Agency to address and suggested that CMS develop a framework document where such questions could be answered – and vetted with stakeholders – prior to any new rulemaking taking place.