Submitted Comments

The Coalition is the respected and credible unified voice of manufacturers of wound care products and technologies. We advocate and educate policymakers, legislators, public and private payers and the other relevant entities to ensure patient and provider access to wound care products and services. We address a broad range of issues and product categories. Our submitted comments are below:

May 9, 2016
The Coalition submitted comments to CMS on to CMS on CMS -1670-P -Medicare Program; Part B Drug Payment Models, requesting that CMS withdraw the proposal entirely. The Coalition believes that the payment model lacks any evidence supporting its methodology. Furthermore, the regulation was proposed without taking stakeholder input into account. The Coalition believes that CMS has not sufficiently proved that their methodology will save costs or improve the quality of care, citing many gaps in the proposal. 
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February 19, 2016
The Coalition submitted comments to CMS on the Medicare Administrative Contractors (MAC) contracting process, as per CMS’ request for information regarding the “Awarding and the Administration of Medicare Administrative Contractor Contracts (CMS 1653-NC).” The Coalition cites past and present accountability and transparency issues with the MACs/PDAC. The Coalition advocates for the extension of this request for information to the PDAC, instead of just the MACs. The Coalition outlines possible incentive systems for exceptional MAC performance, specific metrics or evaluation criteria to measure the quality of MAC service, and the level of information regarding MAC performance that should be public record. 
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