Read Coalition Comments
- Eliminate the new code C1849 ((“Skin substitute, synthetic, resorbable skin substitute per square centimeter) as it is inappropriate and not consistent with the coding for any/all other CTPs,
- Remove placement of the C1849 synthetic CTP products from the high cost tier,
- Require any synthetic CTP to apply for an appropriate HCPCS Q code to be considered a CTP.
The Coalition submitted comments to the CY 2021 proposed physician fee schedule. We:
- Recommended that CMS add codes for disposable negative pressure wound therapy (dNPWT) to the eligible telehealth list,
- Opposed CMS failure to adopt ALL of the RUC recommended work and time values for the revised office visit E/M codes for CY 2021, including and especially the RUC’s recommendation of commensurately including the updated E/M values in procedure codes with 10 and 90 day global periods.
- Delaying the DME competitive bidding program;
- Streamline Medicare billing for disposable negative pressure wound therapy (NPWT) furnished at home onto the standard form used by home health agencies;
- Prioritizing DMEPOS suppliers’ access to personal protective equipment for treating COVID-19 patients in their homes;
- Waiving all pre-authorization requirements for DMEPOS patients during the emergency period;
- Extending appeals deadlines, postponing Medicare audits, and defering overpayment recoupment so that DMEPOS providers and suppliers can focus on caring for patients and provide meaningful products and services to impacted patients;
- Adding select codes for negative pressure wound therapy (NPWT) using disposable, non-durable medical equipment to the eligible telehealth list.
See Coalition Comment
In a letter to CMS, the Coalition requested that a Hospital Harm - Pressure Injury electronic clinical quality measure (eCQM) be included in the CY 2021 Inpatient Prospective Payment System rulemaking. Pressure injury rate transparency will lead hospitals to identify and implement best practice improvements which will reduce hospital-acquired pressure injuries, the Coalition noted.
See Coalition Comment
The Coalition submitted comments to WPS addressing the negative pressure wound therapy (NPWT) provisions of its Draft LCD for Wound Care. The Coalition flagged to WPS that NPWT utilization parameters in its policy conflict with existing DMEMAC policy. The Coalition questioned WPS’ rationale for including NPWT in its policy and recommended that WPS eliminate the information on NPWT in its draft and refer providers to the DMEMAC NPWT Local Coverage Determination.
See Coalition Comments
- CMS should not move forward with a final rule on payment methodologies for DMEPOS until further work is completed.
- CMS should work with stakeholder groups and experts outside of CMS to ensure that the agency has a sufficient understanding of all costs associated with the provision of wound care products and other various types of technology classified under the DMEPOS benefit.
- The Medicare “gap filling” payment determination methodology must be replaced as it is archaic, and does not result in reimbursement rates that allow access to medically necessary technology.
- Fee schedules developed through comparable technology or technology assessments should be transparent and should include manufacturer’s input to ensure a thorough understanding of all associated costs.
- CMS should institute an efficient and expeditious appeals process for manufacturers to challenge reimbursement levels established by this new pricing methodology and gap filling.
- HCPCS public meetings should be limited to input on HCPCS codes, which are universal and as such should be focused on needs of all payers.
- CMS should move quickly in establishing the CTP payment reforms
- CMS must work with wound care stakeholders in creating whatever methodology is ultimately chosen
- CMS must be transparent in providing the data utilized.
- CMS’s revised payment methodology should support reduced copays for Medicare beneficiaries.
- CMS needs to utilize the correct CTP cost information
- CMS must ensure that facilities are billing correctly for CTPs
- CMS must ensure that patients come first and they continue to have access to this valuable adjunctive therapy.
- When CMS proposed packaging, the Agency did not perform an impact analysis on payment rates or patient access. Therefore, CMS must conduct an impact analysis and provide its results in a transparent manner.
- CMS should take into consideration that there are a wide variety of patients with chronic wounds, that wounds heal differently and that treatment is individualized.