✓ We emphasized to CMS the unintended consequences of inconsistent HCPCS coding for CTPs (“skin substitutes”)

In March, the Alliance met with 5 CMS directors and their staff across 3 divisions – the Division of Practitioner Services, the Division of Outpatient Care, and Division of Coding and DRG (who have responsibility for the coding and payment of CTPs) – to discuss how the inconsistent HCPCS code assignments for CTPs and synthetic CTPs has led to problematic issues in both the physician office setting and in hospital outpatient provider-based departments. Under new 2022 policies, which included the assignment of “C” codes and/or “A” codes, there is confusion about how to bill services and products - especially in the HOPD. The Alliance presented six specific recommendations supported by a 35-page chart of relevant HCPCS coding history along with HOPPS & Physician Fee Schedule policies to show how they impact each other. We called on the Agency to bring consistency to coding for CTPs and synthetic CTPs and correct the unintended impacts being experienced under current coding policies.

✓ We pressed for greater transparency and uniformity in development and implementation of coverage issues in co-signed letter to CMS

Led by APMA, the Alliance signed on with more than 18 other organizations to a letter to CMS’ Center for Clinical Standards and Quality addressing issues with LCD/LCA development, CAC issues and the overall lack of transparency and uniformity in stakeholder engagement. Following receipt of the letter, CMS scheduled a meeting to discuss the issues raised. The Alliance collaborated with APMA to help write the letter to include CAC meeting issues that the Alliance had raised in a previous meeting with CMS. Alliance representatives also participated in the February meeting with CMS staff.

The Alliance had spent a substantial amount of time in early 2021 developing comprehensive comments to Noridian’s draft Wound and Ulcer Care LCD. When the final LCD issued in October, we flagged concerns. In response, we were instructed by Noridian to submit a Reconsideration Request. However, the Alliance believes that many of our recommended changes (i.e., fixes to incorrect descriptions of CTP codes and outdated language) are “non-substantive,” meaning that they are clarifying updates that do not change the policy itself and, therefore, can be incorporated without going through the reconsideration process. Our most recent communique to Noridian included a detailed chart of these small but important changes to show how the corrections would add accuracy and clarity to the LCD.

Attended MedPAC virtual meeting in January; alerted members to agenda items that addressed assessing payment adequacy and updating payments.

Participated on CMS “listening sessions” on transitional coverage for emerging technologies, held Feb. 17 & March 31 to help inform CMS’ development of an alternative coverage pathway to provide transitional coverage for emerging technologies. The Alliance had submitted multiple comments to the Agency when the 2021 Medicare Coverage of Innovative Technologies and Reasonable and Necessary proposed rule was being shaped, when the final rule issued, when it was delayed and when it was subsequently repealed. These recent meetings are, we hope, a step forward to help CMS better achieve the goals of timely and predictable Medicare coverage of devices while ensuring that Medicare covers items and services on the basis of sound clinical evidence and with appropriate safeguards.

Alerted to Noridian educational sessions in March on Negative Pressure Wound Therapy and Pneumatic Compression.

Convened in-person Alliance meeting for the first time since the start of the pandemic, with an April 7 gathering for members and guests timed to the Spring SAWC meeting in Phoenix.