Alliance Of Wound Care Stakeholders Inc

TO PROMOTE QUALITY CARE AND PATIENT ACCESS TO WOUND CARE PRODUCTS AND SERVICES THROUGH ADVOCACY IN THE REGULATORY, LEGISLATIVE AND PUBLIC ARENAS.

AS A RESULT OF THE ALLIANCE'S TENACIOUS ADVOCACY WE: CONVINCED CMS TO DELAY AND RE-EVALUATE THE PROBLEMATIC CTP PROVISIONS IN THE 2023 PHYSICIANS FEE SCHEDULE FINAL RULE WHICH INCLUDED: RECLASSIFYING ALL CELLULAR AND TISSUE-BASED PRODUCTS FOR WOUNDS (CTPS, OR SKIN SUBSTITUTES) AS "SUPPLIES INCIDENT TO A PHYSICIAN SERVICE AND PACKAGE PAYMENT INTO PRACTICE EXPENSES AS WELL AS CHANGES IN CODING AND NOMENCLATURE. FOLLOWING TENACIOUS ADVOCACY FOCUSED ON THE BARRIERS TO CARE THIS WOULD CREATE, THESE CHANGES WERE NOT INCLUDED IN THE FINAL 2023 RULE.COMBATTED RESTRICTIVE, CLINICALLY INACCURATE LCDS AND LCAS:ADVOCATED FOR NOVITAS AND FIRST COAST SERVICE OPTIONS (FCSO) TO REVISE ARBITRARY UTILIZATION PARAMETERS AND OTHER KEY PROVISIONS OF THEIR PROPOSED SKIN SUBSTITUTES FOR THE TREATMENT OF DIABETIC FOOT ULCERS AND VENOUS LEG ULCERS LCD/LCA THAT WERE NOT SUPPORTED BY EVIDENCE AND THAT WOULD NEGATIVELY IMPACT PATIENT CARE. ELEVATED THE ISSUE BY SENDING COMMENTS TO THE CEO OF PARENT COMPANY GUIDEWELL. IN RESPONSE, GUIDEWELL'S CLINICAL TEAM STATED THAT DUE TO OUR ADVOCACY THAT WHEN THEY RELEASE THE FINAL LCDS/LCAS, THERE WOULD BE SUBSTANTIVE CHANGES.PURSUED REVISION/WITHDRAWAL OF CGS' PROPOSED LCD/LCA ON SKIN SUBSTITUTES FOR THE TREATMENT OF DIABETIC FOOT ULCERS AND VENOUS LEG ULCERS: FLAGGED CLINICAL INACCURACIES AND LACK OF SUPPORTIVE EVIDENCE. PAVED THE WAY FOR NORIDIAN'S RELEASE OF STALLED CLAIMS. ALLIANCE ADVOCACY PROMPTED THE MAC TO PUBLISH AN UPDATE REPORTING THAT FOR AMNIOTIC AND/OR PLACENTAL DERIVED PRODUCTS "CLAIMS THAT HAVE BEEN PENDING WILL BE RELEASED IN THE UPCOMING DAYS FOR PROCESSING."OBTAINED ENDORSEMENT FROM CMS' ADVISORY PANEL ON HOSPITAL OUTPATIENT PAYMENT FOR THE ALLIANCE'S RECOMMENDATION TO FIX FLAWED/INADEQUATE CTP PAYMENT POLICIES BY ENABLING PROVIDER-BASED DEPARTMENTS TO (1) TO REIMBURSED FOR AN ADEQUATE AMOUNT OF CTP PRODUCTS FOR LARGER WOUNDS AND (2) TO EQUALIZE THE PAYMENT FOR CTP APPLICATION FOR WOUNDS/ULCERS OF THE SAME SIZE NO MATTER THE ANATOMIC LOCATION. THE PANEL SUPPORTED THESE, FOR THE 2ND YEAR IN A ROW, ELEVATED THEM TO CMS FOR CONSIDERATION.BROUGHT ABOUT CHANGES IN THE 2022 CMS NCCI EDIT MANUAL WHICH WAS THE FIRST STEP TO ALLOW FOR REIMBURSEMENT OF THE APPLICATION OF A TOTAL CONTACT CAST OR COMPRESSION THERAPY AFTER A DEBRIDEMENT OR GRAFTING PROCEDURE TO BE PERFORMED AND REPORTED FOR THE SAME PATIENT IN THE SAME ANATOMICAL REGION ON THE SAME DAY. THE ALLIANCE CONTINUES TO MEET AND CORRESPOND WITH THE NCCI CONTRACTOR AND CMS SENIOR STAFF TO DELETE THE NCCI EDITS LISTED IN THE CPT MANUAL AND CMS MANUAL CODING INSTRUCTIONS TO MIRROR AND REFLECT THE GUIDANCE PROVIDED IN ITS RECENTLY UPDATED NCCI POLICY MANUAL.

AS THE ULTIMATE COLLABORATIVE UMBRELLA ORGANIZATION FOR WOUND CARE, THE ALLIANCE CONTINUED TO JOIN FORCES WITH ORGANIZATIONS AND ITS MEMBERS TO IMPACT CHANGE THROUGH THE FOLLOWING EFFORTS:SUCCEEDED IN ENSURING THAT TWO WOUND CARE LEGISLATIVE POLICY PRIORITIES- THE BETTER WOUND CARE AT HOME ACT AND THE LYMPHEDEMA TREATMENT ACT WERE INCLUDED IN H.R. 2617, THE CONSOLIDATED APPROPRIATIONS ACT 2023 THAT PRESIDENT BIDEN SIGNED INTO LAW ON DECEMBER 29, 2022.PRESSED CMS FOR GREATER TRANSPARENCY AND UNIFORMITY IN DEVELOPMENT AND IMPLEMENTATION OF COVERAGE ISSUES AND THE USE OF THE CARRIER ADVISORY COMMITTEES BY MEETING TWICE WITH CMS SENIOR STAFF (PRINCIPAL DEPUTY ADMINISTRATOR JONATHAN BLUM AND COVERAGE STAFF) AND CO-SIGNING LETTER WITH AMERICAN PODIATRIC MEDICAL ASSOCIATION AND 18 ADDITIONAL PHYSICIAN SPECIALTY SOCIETIES.SUPPORTED THE ACADEMY OF NUTRITION AND DIETETICS' SUCCESSFUL CAMPAIGN FOR THE INCLUSION OF THE GLOBAL MALNUTRITION COMPOSITE SCORE IN REGULATIONS BY SUBMITTING COMMENTS TO THE HOSPITAL INPATIENT PPS RULE, SPECIFICALLY SUPPORTING THE INCLUSION OF GLOBAL MALNUTRITION COMPOSITE SCORE (NQF #3592) IN THE PROPOSED POLICY AND RECOMMENDING THAT CMS MOVE FORWARD WITH IMPLEMENTING THE NQF #3592 GLOBAL MALNUTRITION COMPOSITE SCORE FOR THE HOSPITAL INPATIENT QUALITY REPORTING PROGRAM. CMS INCLUDED THIS MEASURE IN ITS IPPS FINAL RULE.SERVED AS A KEY RESOURCE TO THE FDA AS IT PLANNED ITS APRIL WOUNDHEALING SCIENTIFIC WORKSHOP TO SHAPE THE AGENDA, SO IT WAS SYNERGISTIC WITHTHE ALLIANCE'S EVIDENCE SUMMIT.THE ALLIANCE SPOKE AT THE MEETING AND PROVIDED TWO SETS OF COMMENTS TO QUESTIONS POSED BY THE FDA.IN JOINT LETTERS WITH THE CLINICAL LABOR COALITION, REQUESTED CONGRESS' HELP TO ADDRESS THE STEEP REDUCTIONS IN MEDICARE CLINICAL LABOR PAYMENTS THAT STARTED ON JANUARY 1, 2022, AND GO THROUGH CY 2025 FOLLOWING CMS' UPDATE OF THE COSTS OF CLINICAL LABOR IN THE CALCULATION OF PRACTICE EXPENSE RELATIVE VALUE UNITS AN ISSUE THAT IMPACTS MANY WOUND CARE PROVIDERS.PARTNERED WITH 100+ CLINICIAN GROUPS AS PART OF THE CF COALITION IN LETTERS URGING CONGRESS TO TAKE LEGISLATIVE ACTION TO STOP THE 4.5% REDUCTION TO MEDICARE PAYMENT RATES FROM BEING IMPLEMENTED ON JANUARY 1, 2023, UNDER THE 2023 PHYSICIAN FEE SCHEDULE.SERVED ON THE WOUND CARE COLLABORATIVE COMMUNITY STEERING COMMITTEE.

THE ALLIANCE SHAPED POLICY DEVELOPMENT AS WE:URGED NORIDIAN TO FIX INCORRECT AND OUTDATED TERMINOLOGY IN ITS WOUND AND ULCER CARE LCD; SUBMITTED DETAILED CHART OF SMALL BUT IMPORTANT CHANGES (ERRORS IN HCPCS CODING, CPT CODE DESCRIPTORS, OUTDATED LANGUAGE) THAT WOULD NOT REQUIRE RECONSIDERATION PROCESS BUT THAT WOULD ADD ACCURACY AND CLARITY.IMPROVED KEY CMS POLICYMAKERS' UNDERSTANDING OF CTPS VIA TWO MEETINGS WITH CMS STAFF- A MARCH SESSION WITH 5 CMS DIRECTORS AND THEIR STAFFS ACROSS 3 DIVISIONS OF CMS TO DISCUSS HOW THE INCONSISTENT HCPCS CODE ASSIGNMENTS FOR CTPS AND SYNTHETIC CTPS HAS LED TO PROBLEMATIC ISSUES IN BOTH THE PHYSICIAN OFFICE SETTING AND IN HOSPITAL OUTPATIENT PROVIDER-BASED DEPARTMENTS; A JUNE EDUCATIONAL SEMINAR WITH SIX CMS DIRECTORS/DEPUTY DIRECTORS AND 18 SENIOR STAFF TO LEARN MORE ABOUT CTPSTHE DIFFERENT TYPES, CLINICAL CONSIDERATIONS ON THEIR USE, AND REGULATORY PATHWAYS.LED THE INITIATIVE FOR ASTM TO UPDATE THE CTP STANDARD GUIDE (F3163-22) AND ITS DEFINITIONS USED BY PAYERS FOR TERMINOLOGY PURPOSES.