2020 Coalition Achievements

The Coalition Wound Care Manufacturers, as the collective collaborative industry voice, advocates for changes in coding, coverage and payment policies to ensure patient and provider access to wound care products and services. Our role – and impact – was especially crucial in 2020 when the market for wound care products and technologies was shaken up by the public health emergency created by the COVID-19 pandemic. Throughout 2020, the Coalition ensured that regulatory decision makers were aware of real- time barriers faced by the industry, including challenges to specific product categories. We continued tenacious advocacy campaigns to ensure that the value of and need for products was well understood by regulators and properly included in new and developing regulations. Highlights included:
  • Covid-19 Leadership: Expanded Coverage of Surgical Dressings: Assisted in the successful effort to expand coverage of fiber gelling dressings as both primary and secondary dressings by supporting the Alliance’s development of a formal reconsideration request and proposed policy article language. Following our joint advocacy, the DMEMACs updated “Local Coverage Article: Surgical Dressings” to include coverage for secondary, as well as primary, use of alginate and other fiber gelling dressings. Prior to the October 2020 update, these products were only covered when used as primary dressings – which restricted market access.

  • Ensured Appropriate Coverage and Payment for NPWT and dNPWT: Urged CMS to halt MACs from disallowing payment of specific wound care services – including dNPWT specifically – outside of traditional office and hospitals settings, as part of comments on the COVID-19 PHE Second Interim Final Rule. Elevated issue to the Alliance, which submitted a letter to three MACs requesting payment for dNPWT in these sites of service. In response to this joint advocacy, Palmetto stated it would pay for dNPWT in nursing facilities at the applicable Medicare physician non-facility rate.

  • Took Action on Appropriate CTP Coding and Coverage: Voiced concerns with HCPCS coding for synthetic CTPs in the CY2021 Hospital Outpatient Prospective Payment System and offered recommendations for more appropriate coding of the synthetic products; urged CMS to halt MACS from disallowing payment of CTP application outside of traditional office and hospitals settings; and recruited participation from Coalition members to participate in ASTM work group calls to ensure the preservation of the CTP standard F3163, which defines and classifies CTPs.

  • Pursued HCPCS Coding Reform: Participated in meeting as part of the Alliance for HCPCS II Coding Reform (on which the Coalition is a member) with House Energy & Commerce Committee staff to elevate the need for HCPCS coding reform as part of the “Cures 2.0” legislative process. Sent follow-up letter to Congressional leadership to reinforce this issue.

  • Provided Industry Perspective on Key Policies: Advocated for inclusion of a Hospital Harm-Pressure Injury electronic clinical quality measure in the CY 2021 Inpatient Prospective Payment System; Urged CMS to reconsider its proposed new definition of “reasonable and necessary" in the proposed rule regarding Medicare Coverage of Innovative Technology.

  • Helped Create and Shape the Wound Care Evidence Summit (postponed due to COVID-19) to bring together payers, regulators, researchers, clinicians and industry to provide an understanding of what evidence payers require to cover wound care products and procedures. (To be rescheduled.)

  • Monitored policies, flagged issues, alerted members to relevant public meetings and opportunities to comment, and provided access to CMS, DMEMAC and PDAC staff as well as thought leaders and key policy decisionmakers throughout the year.

  • 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 activities, as well as information from prior years, click the links below:

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