Coalition in Action
Q3 2019
Coalition & Alliance Educate CMS Payers and Regulators on Wound Care Issues & Products
The Coalition serves as a unified industry voice to government regulators and payers on behalf of wound care manufacturers. We put this strength on stage on Sept. 9-10 when Palmetto GBA – the new Pricing, Data Analysis and Coding (PDAC) contractor – invited the Coalition and the Alliance of Wound Care Stakeholders to organize and present a seminar on chronic wound care and lymphedema to its new staff and to one of the Durable Medical Equipment Medicare Administrative Contractors (DMEMACs) medical directors.

Last year, we spent a day educating then-PDAC contractor Noridian. This year, we were provided expanded time for a two day seminar. The first day focused on wound assessment, wound healing and the diagnosis/treatment/management of pressure ulcers, venous ulcers, arterial ulcers, diabetic foot ulcers and more. We educated the policy makers about our daily decisions and wound care challenges. Importantly, we also flagged for them several of the LCDs and policy issues that confused or burdened our care and our patients. The second day we focused on lymphedema and its treatments, including pneumatic compression devices.

Then, we hosted a “ show & tell ” where PDAC & DMEMAC staff could see, touch & try different wound care products and treatments to better understand uses and differences. While the primary responsibility of the staffers in attendance have responsibility for coding these products and/or performing medical reviews, many had never directly interacted with the products – and certainly not all of them at one time to see their similarities and differences .
We educated. We advocated. We are hopeful that a more wound- informed staff at the PDAC and DMEMAC will ultimately drive more clinically-accurate coverage policies. And, we now have deeper direct relations with many more PDAC staff and DMEMAC medical directors who know our work and appreciate our perspective.

Thanks to our fabulous team of speakers: Emily Greenstein, Natalie Payne from Smith & Nephew, and Dr. Mark Melin, and to our Coalition members: Smith & Nephew, Acelity and Tactile Medical who supported our efforts by supplying products and clinical educators for our experiential learning and highly engaging “show & tell” session!
Elevating the Coalition Voice in Policy Development:
Submitted Comments
DMEPOS Competitive Bidding
The Coalition counseled CMS on a number of issues in the DMEPOS Competitive Bidding Proposed Rules of the CY2020 End-Stage Renal Disease PPS. We adamantly stressed to CMS that the Agency should not move forward with a final rule on payment methodology for DMEPOS until further work is completed. We recommended that its Medicare “gap filling” payment determination methodology be replaced, as it does not result in reimbursement rates that allow access to medically necessary technology. We asked that fee schedules developed through comparable technology or technology assessments be transparent and include manufacturers’ input to ensure a thorough understanding of all associated costs. Finally, we encouraged CMS to institute an expeditious appeals process for manufacturers to challenge reimbursement levels established by any new pricing methodology and gap filling.

Hospital Outpatient PPS
The Coalition put forward a series of recommendations to CMS related to payment methodologies for CTPs (cellular and tissue-based products for skin wounds). As part of our feedback, we highlighted the need to utilize the correct CTP cost information and ensure that facilities are billing correctly for CTPs.
Elevating the Coalition's Voice in Policy Development:
In-Person Advocacy & Public Meetings
Coalition leadership attended the September MedPAC session focused on “ Examining the effects of competitive bidding for diabetes testing supplies and improving Medicare payment policies for DMEPOS products excluded from competitive bidding .” The MedPAC agreed to request that Congress expand CMS’s authority to included additional products in the competitive bidding program. MedPAC's executive director noted that the first step that MedPAC will take over the next few months is to “think about a set of criteria to identify the kinds of services that are amendable to competitive bidding,” then return to the MedPAC Commissioners with recommendations. See presentations .  
Coalition and Alliance members convened a productive conference call with ASTM representatives regarding the (non-collaborative) leadership of a workgroup that has led recent ballot initiatives that threaten the status of the CTP standard we were instrumental in putting in place in 2015 to accurately define CTP terminology for payer and coverage purposes. We will continue to stay on top of developments and encourage Coalition members who are members of ASTM to remain involved in this issue.
HOP Panel
Marcia Nusgart attended the Aug. 19-20 CMS Advisory Panel on Hospital Outpatient Payment to gain Agency insights, hear the related concerns of other stakeholders and share feedback. ­
CMS Webinars
Coalition leadership participated – and encouraged membership participation ­– on CMS webinars reviewing the proposed updates in the draft CY2020 Physician Fee Schedule & Quality Payment Program regulations that issued over the summer.
Recent Policies & Publications of Interest
CMS’ Physician Compare Now Includes 3 Wound Care Quality Measures
CMS’ Physician Compare website now includes three wound care quality measures following an expansion of quality performance data on the site, pointing – we believe - to a growing appreciation by CMS of the impact of chronic wounds on Medicare beneficiaries. The USWR quality measures selected for Physician Compare reporting were developed by the Alliance of Wound Care Stakeholders together with the US Wound Registry (USWR): (1) Adequate off-loading of diabetic foot ulcer at each treatment visit; (2) Adequate compression of venous leg ulcers at each treatment visit; and (3) Vascular assessment of patients with chronic leg ulcers. See the Alliance’s summary of this progress.

CY2020 Prospective Payment Systems
Coalition members were alerted when CMS published proposed CY2020 updates to the Home Health PPS, the Hospital Outpatient PPS and ESRD/DMEPOS (competitive bidding provisions). We sent a summary of relevant issue to membership and discussed the proposed rules and their potential impact on our monthly calls. Members were instrumental in the developing strategies for comment submission.

Physician Fee Schedule
We shared a summary of the proposed updates to the PFS. While we opted not to submit comments, we did flag specific issues related to CPT code/RUC wound care provisions including open wound debridement, NPWT, and ultrasonic wound assessment and NPWT RUC amounts.

Sunshine for Samples Act of 2019
We informed Coalition membership of the Health subcommittee July mark-up of H.R. 2064, along with related drug pricing and transparency legislation. 
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