in Action
In This Issue: Q1 2020

  • Alliance Leads Wound Care Community’s Rapid Response to COVID-19 Emergency
  • Helps Keep Wound Care Clinics Open with “Wound Care is Essential” Statement
  • Represents the Wound Care Sector with CMS for Regulatory Relief Recommendations
  • Sets Up Online Resource for Wound Care Related COVID-19 Updates
  • Creates Alliance COVID-19 Emergency Fund
  • Co-Hosts Two Webinars - THIS WEEK

  • Submitted Comments
  • CTP payment, topical oxygen therapy, Texas Medicaid & more.

  • Recent Policy Updates
  • Noridian CAC, AHRQ technical brief, President's 2021 budget & more
Alliance Leads Wound Care Community’s Rapid Response to COVID-19 Emergency
The COVID-19 pandemic has driven significant change in the healthcare system, disrupting – indeed transforming – wound care practice. The Alliance of Wound Care Stakeholders is leading the wound care community’s campaign to ensure that wound care is identified as “essential” and well understood by CMS leadership and staff who are developing regulatory relief during the crisis. We are keeping members informed on COVID-19 policy issues impacting them, sharing practice management resources and learning opportunities, and created an Alliance COVID-19 Emergency Fund to support advocacy efforts.

Alliance Statement Keeps Wound Care Clinics Open
In March, it became apparent that wound care clinics were in jeopardy as hospitals began to move resources to support COVID-19 patients. The Alliance acted immediately to convene its diverse membership to craft and issue, in just 48 hours, an emergency statement “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.” Used by clinicians to illustrate to their hospital administrators the value of wound care clinics, this statement has resulted in administrators deciding to keep wound care clinics open across the country.

Alliance Represents Wound Care Sector to CMS for Regulatory Relief Requests
As CMS moves at unprecedented rates to remove regulatory barriers and grant new flexibilities, we immediately galvanized our diverse members – physicians, clinicians and business entities – to identify problematic wound care regulations. We quickly submitted a detailed list of our members’ issues/recommendations in an April letter to the HHS Secretary Azar and CMS Administrator Verma and sent follow up emails to their staff as well as asked questions on CMS' "Office Hours" calls (see details below). We stay current by participating in the multiple CMS health sector conference calls so that we can determine whether our issues are being addressed, plan our next advocacy actions and communicate the most up-to-date information to our membership.

Alliance Creates Central Resource for Wound Care Related COVID-19 Updates
We keep our members informed on an almost daily basis of each new development with proactive emails, conference calls and our new COVID-19 Action and Resource Center The Center is “information central” for wound care doctors, clinicians and business entities Other organizations across the spectrum depend on the Alliance’s website and have quoted Alliance information on their own websites. Changes are happening so quickly that we encourage you to regularly check this page.

Alliance Launches COVID-19 Emergency Fund to Support Advocacy Initiatives
As you will learn in this comprehensive update, while COVID-19 was our top priority in the first quarter, other aspects of wound care coding, coverage and payment continue to require our attention and response. To enable us to continue our important focus on COVID-19 advocacy and education, we are launching the Alliance of Wound Care Stakeholders’ Emergency COVID-19 Fund . Please contribute.

Mark your calendar for learning opportunities THIS WEEK from the Alliance:

Q1 2020 Submitted Comments:
Issues Addressed
Temporary Request Waivers
The Alliance identified policy provisions related to site of service, reimbursement, documentation, DME access and other relevant issues that, with regulatory relief, could remove barriers to treat wound care patients efficiently and effectively during this pandemic. Then, we submitted a detailed request to CMS for temporary regulatory waivers to give flexibility to wound care clinicians. ( see story above. )
CTP Payment Methodologies
The Alliance’s pursued clarity from CMS in a letter flagging the differing interpretations of the three payment methodologies that CMS has been considering in proposed rule making: Episodic Payment, Single APC, and Comprehensive APC. The Alliance specified its understanding of each methodology, informed CMS that "once we come to an understanding of the definitions, we can better offer our specific recommendation" and outlined issues to consider for each methodology. CMS’s Director of the Hospital Outpatient Division quickly responded, noting that “we are happy to consider the Alliance’s recommendations to define such methodologies.” (March)
Texas Medicaid Draft Policy
The Alliance alerted Texas Medicaid to the many provisions within its Draft Policy on Wound Care Management Services that are out of sync with current practice standards - including provisions addressing CTPs, negative pressure wound therapy, surgical dressings, debridement, documentation, prior authorization and more. We provided specific recommendations to update the policy. While generally the Alliance does not tackle state Medicaid issues, an egregious policy from a key state like Texas has the potential to influence other state policies– so addressing these issues early is an important strategy to prevent clinically inaccurate policies from spreading. (February)
Topical Oxygen Therapy
The Alliance submitted comments to the DME MACs' preliminary determination to not cover topical oxygen therapy for would healing, urging the DME MACs to consider the available evidence on a per wound-type basis and make wound type-specific coverage determinations. Importantly, the Alliance also flagged inconsistencies with the LCD development process and CAC meeting compared to the development of other recent LCDs, emphasizing the need for the process to be transparent and consistent across all LCDs and CAC meetings. (February)
GAO Wound Care & CTP Reports
The Government Accountability Office (GAO) reached out to the Alliance for assistance this past February when it was tasked to develop two reports: “How Medicare Provides its Beneficiaries Treatment For Severe Wounds” and “The Impact of Medicare’s Policy for Packaging High-cost Drugs and Biologicals”– including CTPs. The Alliance held a conference call with the GAO to discuss our responses, then followed up by sending answers in writing to additional questions not discussed during the call. We will continue to provide information to the GAO as new questions arise while they write the reports.
Be Up To Speed:
Recent Policy Updates

  • 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 Alliance attended the online meeting and is in the process of briefing Alliance members and planning action items.

  • AHRQ released in February its final version of the CTP Technology Brief. The Alliance had played an active role throughout 2019 in assuring that the assessment followed the appropriate procedural process. 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) As you may recall, we had Dr. Grace Terrell, Co-chair of the PTAC speak to the Alliance at our SAWC Spring meeting.

  • President’s FY2021 Budget: The Trump Administration posted the President’s proposed FY2021 budget. The Alliance flagged and summarized 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)

Welcome to New Members!

Join us in welcoming Advanced Oxygen Therapy Inc. to the Alliance!