Search
About
About Us
Leadership and Staff
Benefits of Membership
Contact Us
Advocacy
Comments
Activities & Accomplishments
Work Plan
Areas of Focus
Policy Tracker
News
Quarterly Newsletter
Coalition in Action Photo Gallery
Calendar
Search
Comments
Items Related to Medicare Administrative Contractors (MACs)
June 22, 2017
Comments to Wisconsin Physician Services (WPS) addressing its draft LCD on Wound Care (DL37228)
The Coalition submitted comments to WPS on wound care draft LCD (DL37228). The comments focus on the arbitrary utilization parameters WPS set for Negative Pressure Wound Therapy (NPWT), stating that parameters do not even necessarily need to be set at all. Furthermore, the Coalition comments that WPS lacks transparency in their decision-making process, and that they should include stakeholder input when crafting their regulations.
View Coalition Comment
March 9, 2017
Comments to First Coast Service Option draft LCD on wound care
The Coalition submitted comments to FCSO on wound care draft LCD (DL37166). The comments focus on the lack of coverage for disposable Negative Pressure Wound Therapy (dNPWT), stressing inaccuracies with CPT coding descriptors and a lack of sufficient evidence to claim that the dNPWT is neither reasonable nor necessary. The Coalition comments that that FCSO should cover dNPWT, providing reasons based on evidence and congressional intent.
View Coalition Comment
March 9, 2017
Comments to Novitas draft LCD on wound care
The Coalition submitted comments to Novitas on draft wound care LCD (DL35125). The comments focus on the lack of coverage for disposable Negative Pressure Wound Therapy (dNPWT), the arbitrary and unnecessary utilization parameters for NPWT, and the lack of transparency in decision-making process for changing the LCD. The Coalition cites evidence that anchors its argument in place.
View Coalition Comment
February 16, 2017
Testimony at FCSO at public meeting on draft wound care LCD
The Coalition provided oral testimony at the FSCO public meeting on February 16 on wound care draft LCD (DL37166). Comments focused on disposable negative pressure wound therapy (dNPWT), concerning utilization parameters and incorrect information contained in the draft LCD.
View Coalition Comment
January 26, 2017
Testimony to Novitas at open meeting to collect comments on its draft LCD on wound care
The Coalition provided oral testimony to Novitas Solutions during its public meeting on wound care draft LCD (DL35125). The Coalition’s comments focus on the drastic difference between the draft LCD compared to its original and that Novitas gives no clear indications as to the reasons for this change. The Coalition also cited specific issues with the arbitrary and non-evidence based utilization parameters for disposable Negative Pressure Wound Therapy. Finally, the Coalition expressed its concerns regarding the confusing and contradictory information contained throughout the LCD, stating that the LCD must be changed and clarified before finalization.
View Coalition Comment
August 8, 2016
Comments to Cigna Government Services on DRAFT Local Coverage Determination (LCD) for Application of Skin Substitute for Wounds, of Lower Extremities (DL36690)
The Coalition submitted comments to Cigna Government Services (CGS) on draft Local Coverage Determination (LCD) for Application of Skin Substitute for Wounds, of Lower Extremities (DL36690), stating that CGS has abandoned the widely accepted CTP nomenclature despite being the first company to recognize it. Specifically, CGS and has reverted to using the scientifically incorrect term “skin-substitutes” in their LCD title language. The Coalition believes that this problematic language causes confusion among the clinical community, resulting in clinical inaccuracies and coverage guidance issues.
view coalition comment
November 27, 2015
Comments to Palmetto GBA on draft LCD “Application of Skin Substitutes to Lower Extremity Chronic Non Healing Wounds”
view coalition comment
October 22, 2015
Testimony at Palmetto GBA public meeting on draft LCD “Application of Skin Substitutes to Lower Extremity Chronic Non Healing Wounds"
view coalition presentation
August 25, 2015
Comments to Palmetto draft LCD on Debridement of Wounds
view coalition comment
July 24, 2015
Coalition comments to Palmetto draft LCD for Application of Skin Substitutes to Lower Extremity Chronic Non Healing Wounds (DL36123)
view coalition comment
May 23, 2015
Comments to First Coast Service Option on draft LCD for Application of Skin Substitute Grafts for Treatment of DFU and VLU of Lower Extremities
view coalition comment
November 6, 2014
Comments to Novitas on draft skin substitute LCD
view coalition comment
July 25, 2014
Comments on the First Coast Service Option’s draft LCD, “Application of Bioengineered Skin Substitutes for the Treatment of Diabetic and Venous Stasis Ulcers of the Lower Extremities”
view coalition comment
November 7, 2013
Comments to Novitas Solutions on Wound Care and Bioengineered Skin Substitutes
view coalition comment
July 18, 2013
Comments to Novitas Solutions on Wound Care and Bioengineered Skin Substitutes
view coalition comment
April 29, 2013
Comments to Cigna Government Services on CTPs
view coalition comment
March 13, 2013
Comments to First Coast on Cellular and/or Tissue Derived Products for Wounds (CTPs)
view coalition comment
July 13, 2012
Comments to Noridian on draft LCD on skin substitutes
view coalition comment
Recent Comments
Comments to CMS CY 2019 Hospital Outpatient Prospective Payment System (OPPS)
Comments to CMS DME/ESRD Prospective Payment System (PPS)
Comments on CMS Pre-Claim Review Demonstration Project for Home Health Services
Email:
marcia@woundcaremanufacturers.org
Phone: 301.530.7846
Fax: 301.530.7946
5225 Pooks Hill Road
Suite 627 South
Bethesda, Maryland 20814
Follow us on: