Alliance Advocacy Update
Q3 2019
CMS Physician Compare Website Now Includes Three Wound Care Quality Measures
Three wound care quality measures developed by the Alliance of Wound Care Stakeholders and the US Wound Registry (USWR) are now included on CMS’ Physician Compare website following an expansion of quality performance data on the site. Physician Compare was created by CMS to enable patients to make informed decisions when selecting Medicare providers by comparing quality data between individual physicians, group practices and ACOs.

The USWR quality measures selected for Physician Compare reporting are:

1.      Adequate off-loading of diabetic foot ulcer at each treatment visit.
2.      Adequate compression of venous leg ulcers at each treatment visit.
3.      Vascular assessment of patients with chronic leg ulcers.

Inclusion of Measures Follows Years of Advocacy on Behalf of Wound Care
Only 11 specialty-specific measure developed by various Qualified Clinical Data Registries (QCDRs) were added to the site, and three of these are our USWR wound care measures . No other QCDR had three measures selected for the Physician Compare site! The prominent positioning of wound management quality measures is, we believe, the result of many years of work by the Alliance and USWR to increase CMS’ attention to chronic wound care and to improve the quality of care provided to patients. This points to a growing appreciation by CMS of the impact of chronic wounds on Medicare beneficiaries.

Have you informed your membership?
Are your members aware of these new publicly available performance measures on Physician Compare? Read and share our Alliance News Update on this top,
or see/share the “ online exclusive ” article in Wound Management and Prevention .
Chronic Wound Care Educational In-Service &
 “Show & Tell” with PDAC & DMEMAC
One of the Alliance’s key strengths is serving as a united, credible and educational voice to government regulators and payers. We put this strength on stage on Sept. 9-10 when Palmetto GBA – the new Pricing, Data Analysis and Coding (PDAC) contractor – invited us 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 and DMEMAC staffers and medical directors who know our work and appreciate our credibility and objectivity.

Thanks to our fabulous team of speakers: Emily Greenstein, Natalie Payne and Dr. Mark Melin, and to Alliance and Coalition of Wound Care Manufacturer members Smith & Nephew, Acelity, AMT Technologies, Prism Medical, Tactile Medical, Lympha Press, Bio Compression Systems Inc. and Wound Zoom who supported our efforts by supplying products and clinical educators for our experiential learning and highly engaging “show & tell” session!
Elevating the Alliance Voice in Policy Development via
Submitted Comments
Hospital Outpatient PPS
Alliance comments to proposed CY2020 Hospital Outpatient Prospective Payment System updates flagged concerns on a topics including the (1) broad sweep to move all outpatient therapeutic services from direct to general supervision ; (2) prior authorization for several new procedures often used to treat wounds; (3) proposed payment methodologies for CTPs .
Physician Fee Schedule
Alliance comments addressed a range of provisions that impact wound care providers, including: (1) Evaluation and Management Codes; (2) Relative Value Units (RVUs) for physical therapy (3) Practice Expense RVUs for disposable negative pressure wound therapy; (4) open wound debridement; and (5) ultrasonic wound assessment.

Home Health PPS
Alliance comments flagged concern with the proposal to reduce the Requests for Anticipated Payment and we opposed the removal of pain measures from the Home Health Quality Reporting Program and Home Health Consumer Assessment of Healthcare Providers & Systems.
Patients Over Paperwork
The Alliance provided input to CMS’ Request for Information regarding Patients Over Paperwork initiatives related to reporting, coding & documentation requirements. Comments focused on NCCI edits, HCPCS coding reform, local coverage decisions versus coverage articles, prior authorization, and billing for disposable NPWT the home health setting.
AHRQ RFI on Evidence Reviews
The Alliance responded to AHRQ's request for information on "The Impact and Use of Evidence-Based Practice Center Evidence Reviews" with comments that respectfully noted that reviews in the wound care space tend to be "myopic," with significant errors and key questions that are too narrowly focused to impact coverage. We provided specific suggestions on how the evidence reviews can be more useful to our space.
AHRQ “Skin Substitutes for Treating Chronic Wounds”
Alliance comments to the draft technical brief raised concern that only 3 of the 83 studies submitted were accepted for consideration - excluding of most of the evidence submitted from the expanded evidence search that had deliberately been re-opened. We urged AHRQ to release the next draft of the technical review with an additional public comment period.

In Development: Comments on new WPS wound care LCD
In September, Wisconsin Physician Services (WPS) released a LCD focused on debridement in draft form, again, in response to both formal and informal reconsideration requests. We are concerned about the non-coverage of debridement for diabetic foot ulcers/stage II pressure ulcers. We quickly circulated an assessment of the LCD and sent a “call to action” to members requesting attendance and/or presentation of feedback at the WPS Oct. 21 public meeting . Comment deadline is Nov. 10.  
Alliance In-Person Advocacy & Key Q3 Meetings
Alliance leadership attended the Sept. 5 MedPAC session on competitive bidding. The MedPAC agreed to request that Congress expand CMS’s authority to included additional products in the competitive bidding program. The MedPAC executive director noted that MedPAC will “think about a set of criteria to identify the kinds of services that are amendable to competitive bidding,” then return with recommendations. See presentations and transcript
HOP Advisory Panel
Alliance leadership and members attended the Aug. 19-20 CMS Advisory Panel on Hospital Outpatient Payment to gain Agency insights and share our own feedback. Alliance members Dr. Arti Masturzo and Mike Pratscher provided oral testimony at that meeting. 
CMS Webinars
Alliance leadership participated on – and encouraged membership participation on – CMS webinars reviewing the proposed updates in the draft CY2020 Physician Fee Schedule and Quality Payment Program regulations that issued over the summer.
Alliance members convened a productive conference call with ASTM representatives regarding the focus and (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.
Upcoming Meetings:
SAWC Fall:  If you are attending the Fall SAWC meeting, join us at our in-person meeting Sat., Oct. 12 at 1:15-3:15 PT in the Pompeian I room at Caesars Palace.

WPS Open Meeting:  A  public meeting/ conference call hosted by WPS on Oct. 21 from 1:30-3:30 PT will enable stakeholders to address its draft LCD on wound care (DL37228). The Alliance will be participating. The policy will also be discussed at WPS’  LCD Contractor Advisory Committee (CAC)  on October 24 at 4:00 PM CT. 

Health Care Payment and Learning Action Network:  The  Fall Summit  in Washington DC on Oct. 24 features speakers from CMS, CMMI, Anthem, Humana, PCORI, National Quality Forum and more. Registration is free.
Welcome to New Members!
Welcome to our newest clinical association member, the  Wound Healing Society ,  and to our two new business entity members,   MolecuLight  and  Tides Medical .
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