2017 Coalition Achievements

Throughout 2017, the Coalition provided a unified wound care perspective to CMS and its contractors, FDA, Capitol Hill and other key policy stakeholders in the wound care space. We identified and took advantage of multiple opportunities for input, advocacy, and comment. We worked tirelessly to ensure that regulatory agencies were aware of the issues and impacts to wound care as policies were crafted and considered. Our comments put us “on the record,” built credibility and opened doors for ongoing advocacy and dialogue. Having a strong, united voice as policies and regulations are drafted in today’s hyper-partisan world remained essential throughout 2017 and looking ahead to the future. Key Coalition accomplishments and activities in 2017 included:

Went on the Record with comments & Testimony 11 times in 2017 

Advocated for fair, rational and clinically/procedurally-sound policies to Congress, HHS, CMS and its contractors by submitting 11 sets of comments, oral testimonies, and letters.
  • 2 comments to CMS on CY2018 Hospital Outpatient PPS and Physician Fee Schedule.
  • 5 comments to A/B MACs addressing Novitas, WPS and FirstCoast LCDs. 
  • 1 letter to DMEMACs continuing to raise concerns with the final surgical dressing LCD. 
  • 1 letter to HHS and CMS, co-signed with the Alliance for HCPCS II Coding Reform. 
  • 2 letters to Congress members addressing competitive bidding/HCPCS coding (then-Rep. Tom Price) and voicing support for support the “DMEPOS Access and Transparency Act of 2017” (Rep. Marsha Blackburn). 

Minimized the impact of a restrictive Lcd on npwt

Positively influenced and minimized the impact of a restrictive draft LCD on negative pressure wound therapy (NPWT). The Alliance actively responded to a concerning Novitas wound care local coverage determination (LCD) issued in January. We testified at Novitas’ public meeting and submitted comments recording concern about the lack of evidence to support the proposed changes, the elimination of coverage of disposable Negative Pressure Wound Therapy (dNPWT), and the arbitrary utilization parameters set for NPWT and debridement services. The final policy, published in Sept., resolved many of our comments and ultimately included coverage for dNPWT plus more flexibility in performing NPWT.

Advocated for meaningul clarifications to the dmemac surgical dressing lcd

Applied proactive, tenacious advocacy to address clinical concerns with the DMEMAC final surgical dressing LCD, ultimately driving a “clarification letter” addressing several key issues. The final policy (published in June) was not consistent with how surgical dressing products are prescribed and utilized by wound care clinicians. We collaborated with the Alliance of Wound Care Stakeholders to coordinate a synergistic advocacy strategy. Our advocacy did achieve action and DMEMAC response in the form of a "clarification letter" that addressed several of the key areas of the LCD that were causing confusion in clinical practice and impacting patient care/patient access to products and services.

Pursued accurate and clinically sound local coverage determinations (LCDs)

Maintained persistent advocacy with A/B MAC and DMEMAC medical directors for fair and equitable LCD and coverage processes. The Coalition testified at two public meetings and submitted three written comments on draft wound care LCDs in 2017.

Mobilized  PDAC to modernize its Coding Verification Application 

Medicare’s Pricing, Data Analysis and Coding Contractor (PDAC) took action following Coalition advocacy efforts. The Coalition played a significant role in prompting the update, following our previous submission of questions and requests for clarity surrounding the current application process. The Coalition members served as a resource on updating the Coding Verification Application. In addition, as an outcome of our inquiry and identification of concerns, the PDAC is in the process of updating content and instructions on its website. 

Elevated the need for hcpcs coding reform

Elevated the need for HCPCS coding reform to ultimately help improve patient access to medically necessary products and simplify the process for manufacturers to bring products to the wound marketplace. In collaboration with the Alliance for HCPCS II Coding Reform, the Coalition co-signed a letter to (then) HHS Secretary Tom Price and CMS Administrator Seema Verma expressing concerns with the current coding process and asking CMS to (1) Increase transparency of coding decisions; (2) Separate criteria used to establish a new HCPCS code from criteria used to establish a coverage policy for the product; (3) Establish an appeals process to provide independent review/reconsideration of coding decisions and (4) Improve the PDAC coding verification and code revision processes. 

supported the Alliance of Wound Care Stakeholders

Served as an active supporter and participant in Alliance of Wound Care Stakeholders activities to ensure that the wound care provider clinical expert voice is proactively speaking to the impact of policies on patients and providers (See www.woundcarestakeholders.org).

For more detailed information on 2017 activities, as well as information from prior years, click the links below:

Email: marcia@woundcaremanufacturers.org 
Phone: 301.530.7846 
Fax: 301.530.7946
5225 Pooks Hill Road 
Suite 627 South 
Bethesda, Maryland 20814
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