✓ We engaged support of HOPPS Advisory Panel to correct flaws in CTP payments and enable Provider-Based Departments to be fairly reimbursed.

In a huge advocacy win, following the Alliance’s presentation at the Medicare Advisory Panel on Hospital Outpatient Payment (HOPPS), the Panel unanimously approved our two recommendations to correct flaws in payments for cellular and/or tissue-based products for skin wounds (CTPs) and enable Provider-Based Departments to be fairly reimbursed. The recommendations focused on updating HOPPS to include adequate payment to purchase the additional sq. cm. of CTPs for larger wounds and adjusting provisions so that all anatomic locations of the same size wound be paid the same - as they require the same amount of product to be purchased. These recommendations were endorsed by the panel to CMS, as well as reiterated by the Alliance in our comments on the CY2022 Hospital Outpatient Prospective Payment System submitted to the Agency in September.

✓ We challenged CMS’ ongoing deferral of HCPCS coding requests for CTPs, urged of new codes

Alliance Executive Director Marcia Nusgart spoke at CMS’ July HCPCS public meeting, supporting HCPCS Workgroup’s decision to issue a new code for the non-pneumatic compression system and urging the Agency to establish new HCPCS codes for the CTPs. When CMS once again indicated that it will continue to defer coding requests for CTPs to a subsequent coding cycle “because the scope of the request necessitates that additional consideration be given before CMS reaches a final decision,” the Alliance convened a call with CMS staff to better understand what “additional considerations” CMS needs, so that they could be directly addressed to avoid further delays in patient/provider access to CTP products.

✓ We supported legislation to provide Medicare coverage of compression supplies for patients with lymphedema.

The Alliance submitted an August letter to Congress supporting the Lymphedema Treatment Act (S.1315/H.R. 3630), legislation that would provide more comprehensive Medicare coverage for the treatment of patients with lymphedema or for the prevention of venous stasis ulcers resulting from venous insufficiency. The legislation would amend Medicare statutes to allow for coverage of compression supplies, and longer term, could set a precedent for Medicaid and private insurers to follow. 

✓ We requested a meeting with NCCI contractor to address problematic edits regarding compression, CTP application and debridement 

The Alliance submitted a letter to the National Correct Coding Initiative (NCCI) contractor reiterating that current edits addressing compression, CTP application and debridement are inconsistent with peer-reviewed literature and do not allow the accurate allocation of resources for clinical procedures to deliver the most effective clinical approaches for diabetic foot ulcers and venous ulcers. A follow-up to the Alliance's June comments, our October letter requested a meeting with the NCCI contractor and appropriate CMS staff to further discuss the issue.

Wound Healing Science & Industry conference: Marcia Nusgart joined other thought leaders in wound care on a “think tank panel” focused on “Wound and Vascular Care in a Post-Covid World - AI, Telemedicine, and the Shifting Points of Care.” (Oct.)

Board and workgroup meetings: The Alliance’s board convened virtually on July 9 to discuss business issues and opportunities, with a particular focus on potential new membership categories and strategic planning for the 2022 Wound Care Evidence Summit. Our CTP workgroup convened on Aug. 2 to continue to shape comments to provisions in the CY2022 HOPPS impacting payment for this product category. The Government Affairs workgroup met Aug. 16 to discuss letters of support for legislation impacting wound care (see above).