in Action
In This Issue: Q3 2020

  • Advocacy Win!
  • DMEMACs Change Regulations to Allow Coverage for Alginate and/or other Fiber Gelling Dressings as both Primary and Secondary Dressings

  • Q3 Comments & Meetings
  • Alliance weighs in on CY2021 Physician Fee Schedule, Hospital Outpatient Prospective Payment System and COVID-19 regulations. Comments to Congress, USP & more.

  • Recent Policy Updates

  • Welcome to our newest board member: Dr. Lee Rogers
Dear Alliance members,

We’re pleased to share with you a major win: after a year of Alliance advocacy, CMS’ Durable Medical Equipment Medicare Administrative Contractors (DMEMACs) recently updated a key surgical dressings policy article. CMS will now allow “Alginate and/or other Fiber Gelling Dressings” to be covered (and paid for) as both primary and secondary dressings for Medicare patients. This announcement was made in an October 15, 2020 Policy Article update (A54563).

Previously, although these products were developed as both primary and secondary dressings, they could only be billed under Medicare as primary dressings – limiting healthcare providers’ discretion and choices in properly treating wound patients.

This update is a direct result of the Alliance’s tenacious advocacy, months of conversations and negotiations with the DMEMAC medical directors as well as our submission of specific policy language for consideration. Thank you to our clinical associations (especially AAWC and WOCN) and our business entities who provided the necessary surgical dressing expertise in our conference calls with the medical directors.

This is a terrific illustration of how our voices joined together through the Alliance can change regulations and protect access to products and services for people with wounds and practitioners who treat them.

Congratulations to all who participated in our work to make this policy update happen!
Caroline E. Fife MD, Matthew G. Garoufalis DPM; Co-chairs
Marcia Nusgart, RPh; Executive Director
Alliance of Wound Care Stakeholders
Recent Comments & Activities:
We opposed payment cuts for physician and physical therapy services. 
Why is this important? We stood in unison with physician specialty societies and clinical associations by opposing significant physician and PT service cuts in comments submitted to CMS’ Proposed CY2021 Physician Fee Schedule. (October)
We urged USP to create a wound care subcategory.
Why is this important? Establishment of a distinct wound care subcategory in United States Pharmacopeia’s Medicare Model Guidelines (instead of being included in the generic “dermatological – other” subcategory) would help to distinguish chronic wound care products from other subcategories, which in turn would better protect their coverage under Medicare Part D. We educated USP leadership via a (virtual) meeting and submitted a letter advocating the need. This followed our 2019 letter to USP on this topic. We also provided to our members a specific link to submit comments on the USP DC website. (October)
We voiced concern about proposed new “C code” for synthetic CTPs.
Why is this important? The Alliance supported inclusion of synthetic CTPs in the definition of “skin substitutes”/CTPs but expressed significant concerns with the Agency’s proposed establishment of a unique HCPCS “C” code (usually used for items with pass through status) to define an entire class of products with a broad code descriptor and assigning them to the OPPS high cost payment package. Generally, all other CTPs are required to apply for and obtain a unique HCPCS “Q” code which is product and brand specific. Our comments to CMS’ proposed CY2021 Hospital Outpatient Payment System alerted the agency to its inconsistency and the confusion this could result in. We offered specific recommendations for more appropriate coding of the synthetic products. (October)
We flagged concern with Congressional legislation impacting Medicare pass-through status.
Why is this important? The Alliance co-signed a letter to the Senate Finance Committee expressing concern regarding legislation (S. 4295) that would allow Health and Human Services to extend the period of Medicare pass-through status in the hospital outpatient setting to any product with that status during the COVID public health emergency. Our letter flagged the impact such a pass-through extension would have on CTPs and noted the importance of ensuring access to all CTP products in the market to support clinical choice and patient value. (August)
We urged Congress to include HCPCS coding reform provisions in Cures 2.0 legislation.
Why is this important? The current HCPCS coding process significantly hinders Medicare patients’ access to innovative medical devices and technologies. As a member of the Alliance for HCPCS Coding Reform, we submitted a letter to Representatives DeGette (D-CO) and Upton (R-MI) urging that the upcoming Cures 2.0 legislative package include language to reform and modernize HCPCS Level II coding to ensure that the process is fair, transparent, predictable, accurate, efficient, and independent of a payer’s coverage and payment considerations.
We called on CMS to modify select coverage/payment policies that were specifically impacting wound care during the pandemic.
Why is this important? We worked to ensure that CMS makes COVID-related wound care coverage and payment decisions based on the real-world, front-line experience of wound care practitioners. The coronavirus has drastically changed how and where wound care providers treat their patients. Our comments provided specific recommendations to CMS on how temporary rules, waivers and policies should evolve to reflect this new world. (July)
We successfully educated DMEMAC medical directors to issue a surgical dressing policy article update covering fiber gelling dressings as both primary and secondary dressings.
Why is this important? The Alliance was persistent in our advocacy, and this tenaciousness delivered results. We convened multiple calls with the DMEMAC medical directors, clinicians and business entities with expertise in this space. We assembled and provided clinical evidence. We educated DMEMAC staff on primary vs. secondary dressings. We submitted a formal reconsideration request, then at the advice of DMEMAC leadership, withdrew the reconsideration request and instead submitted clarifying language for a policy article – which would ultimately be easier and quicker to implement. The result: an updated policy article published on Oct. 15. 2020, and a correct coding article from the DMEMACs is expected to be forthcoming!
(See “Dear Alliance” letter above.)
Q3 Meetings:
Hospital Outpatient Advisory Panel: The Alliance spoke at the CMS’ Advisory Panel on Hospital Outpatient Payment Meeting to flag our issues and concerns on provisions impacting wound care in the CY 2021 Hospital Outpatient PPS proposed rule (August)
MedPAC: We virtually attended MedPAC meeting sessions on Medicare payment policy and telehealth, then provided a summary to members. (September)
HMP Webinar: We recorded a webinar for HMP’s Wound Care Learning Network with Dr Paul Kim, Marcia Nusgart and Karen Ravitz on the impacts of Covid-19 on wound care.
Be Up To Speed:
Recent Policy Updates Relevant to Wound Care
  • Novitas and First Coast announced the retiring of their Local Coverage Determinations (LCDs) for Hyperbaric Oxygen Therapy (HBOT). Because a National Coverage Determination (NCD) for HBOT remains in place, theoretically, coverage for HBOT should not change as a result of the retiring of these LCDs. Yet, we will continue to follow this issue. (September)

  • CMS released proposed rule “Medicare Coverage of Innovative Technology (MCIT) for comment. The Alliance provided members opportunity to glean important insights on the proposed rule by featuring guest speaker Lesley C. Reynolds from the law firm Reed Smith on our monthly Alliance call. As Lesley shared, the rule has many provisions that may impact Alliance clinical and business members. The Alliance is in the process of preparing comments. (September)
Welcome to our New Board Member:
Dr. Lee Rogers
We are excited to inform you that Lee C. Rogers, DPM, co-founder of the Amputation Prevention Centers of America, has joined the Alliance board of directors. Dr. Rogers is a member of the board of directors of the American Board of Podiatric Medicine, a past chair of the foot care council of the American Diabetes Association and actively involved in Diabetic Foot International.

He has been selected by Podiatry Management Magazine as one of the most influential podiatrists in America. He brings significant political insights and expertise to our board: in 2012 and 2014, Dr. Rogers was a candidate for US Congress from Los Angeles, endorsed by the LA Times, the LA Mayor, California Lt. Governor and about 40 members of Congress.
Keep Up With Clinical Association Colleagues:
Curious what your clinical association colleagues are up to? Keep up with your clinical association colleagues during these crazy times. Check out a few of our member clinical associations’ recent newsletters and blogs:

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