Submitted Comments

In both oral and written comments submitted to Noridian regarding its draft wound care LCD (DL38902) , the Coalition flagged two key issues for the MAC to address: an incorrect definition of “advanced dressings” that needs to be expanded, and inconsistencies between the LCD (DL38902) and its accompanying LCA on billing and coding (DA58565) that have the effect of placing limits on debridement utilization parameters that are not included in the LCD. 

See Coalition Comments

The Coalition submitted comments to CMS' proposed rule regarding Medicare Coverage of Innovative Technology (MCIT) and the new definition of “reasonable and necessary." The Coalition encouraged CMS to establish a payment system for MCIT devices allowing for appropriate reimbursement - as without appropriate payment, the expanded MCIT coverage will be meaningless. We also recommended inclusion of provisions preventing the MACs from denying coverage of any technology eligible for new technology add-on payments or transitional passthrough payments. With regard to "reasonable and necessary," the Coalition expressed concerned about language which permits CMS to use commercial insurance medical policies for Medicare purposes.  "The Coalition is extremely concerned that CMS will cherry pick commercial payers that restrict coverage and therefore," we wrote in comments. "At this time, we do not support any definition of 'reasonable and necessary' that goes outside of what has already been published and adhered to in the Program Integrity Manual."
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• CMS

The Coalition submitted comments to CMS' Proposed CY2021 Hospital Outpatient Prospective Payment System. Our comments primarily focused on the provisions relating to synthetic CTPS, and we urged CMS to:

• 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.

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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.

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• CMS
• Negative Pressure Wound Therapy (NPWT)

The Coalition submitted comments to CMS's COVID-19 Public Health Emergency Second Interim Final Rule that provided additional policy and regulatory revisions to provide flexibility during the pandemic. The Coalition focused on issues facing the wound care supplier and manufacturing communities, with specific recommendations for CMS to consider. These included:

• 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.

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Following a February 2020 comment letter to CMS requesting that  a Hospital Harm - Pressure Injury electronic clinical quality measure (eCQM) be included in the CY 2021 Inpatient Prospective Payment System rulemaking, the Coalition sent a June follow-on communique to the Agency noting "While this measure was included in the proposed CY 2020 rulemaking, it was not included in the final CY 2020 Inpatient PPS rule nor was it included in the recent CY 2021 proposed rule.  We are disappointed that the Agency did not include these measures and hope that the Agency reconsiders placing it into the CY 2021 final rule or at the very least propose its inclusion in the CY 2022 proposed rule."

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SEE COALITION LETTER 

• DMEMACs
• Negative Pressure Wound Therapy (NPWT)

The Coalition submitted inputs in response to CMS’ request for comments on surveys to improve the monitoring, outreach, and enforcement functions of the durable medical equipment, prosthetics, orthotics and supplies (DMEPOS) competitive bidding program (CBP). The Coalition provided recommendations on timing, frequency and transparency. 
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.
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• DMEMACs
• Negative Pressure Wound Therapy (NPWT)

The Coalition submitted comments to the DMEPOS Competitive Bidding Proposed Amendments included in CMS's CY 2020 End-Stage Renal Disease Prospective Payment System. In comments specifically focused on the provisions related to "Establishing Payment Amounts for New Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) Items and Services (Gap-filling)," the Coalition counseled CMS on a number of issues, flagging concerns and suggesting solutions:

• 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.

See Coalition comments

• CMS
• Competitive Bidding