Coalition in Action
Q1 2020

Protecting Wound Care & Addressing Manufacturer Issues
Amid the COVID-19 Pandemic

The COVID-19 pandemic is driving significant change in the healthcare system, disrupting – and indeed transforming - wound care practice as we know it. Government agencies are moving at impressive speed to remove regulatory barriers and grant new flexibilities so that medicine across specialties can be practiced at different sites of care, in the virtual space and beyond. Importantly, the Coalition, together with our colleagues at the Alliance of Wound Care Stakeholders, has had a voice in ensuring that wound care patients are protected , that the needs of wound care providers are met, and that the concerns of wound care manufacturers are addressed.  

The we and the larger wound care community has been working together in an impressive number of ways:

1. Position Statement Keeps Wound Care Clinics Open
The Alliance (of which the Coalition is a member) developed and issued a position statement to support designating wound care treatments and procedures as essential: “ Wound Care is an Essential – Not Elective – Service that Prevents Hospital Admissions and ED Visits Among a Fragile Cohort of Patients at High-Risk of COVID-19. ” This position statement has been used by wound centers to clarify the role the wound care can play in preventing hospital readmissions and other unintended consequences… and helped many wound centers to stay open to treat their patients. This outcome is of course important to manufacturers that sell products to wound care centers!

2. Regulatory Relief Targeted to Wound Care Clinicians & Manufacturers
Coalition members provided recommendations which we sent to CMS regarding COVID-19 regulatory relief on manufacturer billing and other issues to ensure that wound care patients would receive the necessary products. These issues addressed copays, CTPs, virtual demonstration for pneumatic compression devices, supervision requirement, and specific surgical dressing issues. Recommendations went to our colleagues on the Alliance, who took the lead on submitting a letter to HHS/CMS requesting temporary regulatory waivers to give flexibility to wound care clinicians to provide necessary procedures and products to treat their patients amid the evolving realities of the pandemic. (April)

3. COVID-19 Wound Care Action & Resources Center
The COVID-19 Action and Resource Center has been created on the Alliance’s website to serve as “information central” for wound care  doctors, clinicians and business entities. The resource center includes information on relevant policies, articles and learning opportunities. In addition, via a regular series of emails, we’ve been keeping the Coalition up to date on evolving policy announcements so members can quickly understand the specific impacts, as well as keeping membership informed of CMS “office hours,” “open door forums,” webinars, and other info sessions.

4. COVID-19 Emergency Fund Supports Advocacy Initiatives
To enable a continued focus on COVID-19 advocacy specific to wound care, the  Alliance of Wound Care Stakeholders’ Emergency COVID-19 Fund was created. You’ve seen firsthand how quickly new issues are arising that challenge wound care providers’ ability to care safely for patients. It takes a tremendous effort to stay on top of each evolving policy change, interpret the specific implications for wound care, and  galvanize diverse stakeholders into a strong, single voice to defend essential wound care services. Please join the other wound care manufacturers, suppliers, distributors, clinics and innovators who are stepping up to the plate to ensure that the Alliance can continue its tremendous advocacy and education efforts to protect wound care practice and patients.
Please consider a corporate contribution to provide the resources needed to continue this advocacy battle.
Elevating the Coalition's Voice in Policy Development:
Comments & Meetings
Pressure Injury Quality Measures
The Coalition requested that a Hospital Harm - Pressure Injury electronic clinical quality measure (eCQM) be included in the CY 2021 Inpatient Prospective Payment System rule making. The Coalition noted in its submitted comments that pressure injury rate transparency will lead hospitals to identify and implement best practice improvements which will reduce hospital-acquired pressure injuries. (February)

HCPCS Coding Reform
Alliance for HCPCS Coding Reform (of which the Coalition is a member) met with staff from the House Energy and Commerce Committee to elevate issues with the HCPCS coding process that could be addressed in the evolving “Cures 2.0” legislation.  
CTP Payment Methodologies
Coalition staff sought input from CTP manufacturers on their evolving perspectives on the three CTP payment methodologies under consideration by CMS. (The Coalition itself has not yet created a unified position until more information is provided by CMS.) We shared inputs with the Alliance, who in turn submitted a letter to CMS to clarify the definitions of each of the proposed CTP payment methodologies - Episodic Payment, Single APC, and Comprehensive APC. (March)

Temporary Waiver Request
We reached out to Coalition membership for suggestions to send to CMS on COVID-19 regulatory relief for supplying wound care products to wound care patients. ( see article above. )
Surgical Dressing Reconsideration
The Coalition sought input on issues that should be raised in a surgical dressing reconsideration initiative. Inputs were passed along to the Alliance of Wound Care Stakeholders’ work group, which is taking the lead on a reconsideration request to change language in the alginate and fiber gelling category to include their use as both a primary and secondary dressing.  

Recent Policies & Publications of Interest
We circulated to Coalition members emails and updates about the following policies and issues as they occurred over the first quarter:

Noridian CAC Noridian convened a Contractor Advisory Committee (CAC) on Wound Care and CTPs on April 28th to discuss the clinical literature related to Wound Care as well as for CTPs and rate their confidence in a series of key questions. The Coalition staff attended the online call and addressed the issues during the monthly Coalition calls.

AHRQ   released in February its final version of the  CTP Technology Brief – which had been the focus of Coalition advocacy work in 2019 when we collaborated with the Alliance to have expanded evidence considered. The Agency also this quarter requested supplemental evidence and data for its Technology Assessment on Platelet-rich Plasma for Wound Care.

PTAC : HHS released its  response  to the report from the Physician-Focused Payment Model Technical Advisory Committee addressing wound care payment recommendations. (February)

DMEMACs :  The DMEMACs made several revisions to the  surgical dressing LCD  and  surgical dressing policy article   (January, March).

President’s FY2021 Budget : The Trump Administration posted the President’s proposed FY2021  budget . The Coalition flagged to members provisions of interest to wound care - including a proposal to allow CMS to drive down DMEPOS prices without going through the IR process and a plan to improve the clarity of the coverage process. (February)

Check the  C OVID-19 Action & Resource Center   for relevant policy updates specific to wound care practice amid the pandemic.
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