Alliance of Wound Care Stakeholders Advocacy Update

Alliance Educates PDAC & DMEMAC via a "Show & Tell" Seminar Enabling Staff to See/Touch/Feel Key Wound Care Products

One of the Alliance's key strengths is serving as a united, credible and educational voice to government regulators and payers. We put this strength on stage this month: In collaboration with the Coalition of Wound Care Manufacturers we convened an educational session on chronic wound care for the Medical Directors and the staffs of both the Pricing, Data Analysis and Coding (PDAC) and the Durable Medical Equipment Medicare Administrative Contractors (DMEMACS).

Over the past few years, the Alliance has submitted numerous comments to DMEMACS and PDAC - including a recent series of comments to the DMEMACS noting our concerns with the surgical dressing LCD finalized in June 2017. While we didn't achieve all of the changes we wanted, we ensured that issues were clarified to ensure that the LCD was workable in the real-world clinical setting. And we bolstered our reputation as a credible, collaborative advocate on wound care issues - so much so that we were invited to lead an in-service educational session on chronic wound care!

What we did

On April 12, we convened more than 50 PDAC/DMEMAC staff and Medical Directors at Noridian's offices in Fargo, ND for a full-day educational session that addressed topics including: the phases of wound healing; wound and skin assessment; measurement and documentation; diagnosis and treatment of pressure, diabetic, vascular and arterial ulcers; wound bed preparation; and of course, clinical considerations when selecting dressings/procedures. We made the audience aware of instances where the current surgical dressing LCD conflicted with good clinical practice and validated our information with references and listing of clinical journals. We had two phenomenal clinicians as speakers (Emily Greenstein and Natalie Payne) who captivated the audience with not only the scientific information but also real-life experiences in treating patients with wounds. Five Alliance/Coalition business entities supported the effort: Acelity, Medela, Mölnlycke Health Care, Smith & Nephew and Prism Medical.

The educational power of "show & tell"

As part of our talks, we distributed samples of more than 15 product categories of surgical dressings which had HCPCS codes assigned to them. Each attendee had samples of such diverse products as collagen, hydrogel, foam and hydrocolloid dressings that they could see, touch and feel. Speakers spent time discussing each surgical dressing category in the order of absorbing exudate and then passed out the different dressings so that each attendee could see the different sizes, shapes, etc. and understand better their uses. Speakers also spent time addressing NPWT and demonstrated NPWT devices for the audience. Disposable NPWT and CTPs were also discussed - even though these are covered under the A/B MACs rather than DMEMACs - as we wanted to demonstrate the variety of products and procedures that clinicians can use in treating wounds. 

While many of the staffers in attendance have responsibility for coding these products and/or performing medical review and claims processing, many had never directly interacted with the products - and certainly not all of them at one time. It was if we brought the wound care convention hall floor to them!  If a picture is worth 1,000 words, then being able to physically see and maneuver each product was priceless.

Impacts & benefits moving forward

The PDAC and DMEMAC Medical Director and their staffs were extremely grateful for the educational seminar and thanked us for traveling all the way to Fargo! They shared that they were impressed with the quality and depth of the material and inquired we could potentially repeat the session for staff in other Medicare jurisdictions.

We are optimistic that the deep educational dive into wound care will ultimately aid PDAC and DMEMAC staff in their respective positions. The PDAC staff decide which HCPCS code the product falls into when manufacturers submit coding verification applications. The DMEMAC staff in attendance perform medical reviews, claims processing, and help develop coverage policies.

We have seen misinformation about wound care impact HCPCS coding, impact local coverage determinations and impact claims denials. We are hopeful that a more wound- informed staff at the PDAC and DMEMAC will ultimately drive more clinically-accurate coverage policies. And until that time that we see perfectly-crafted wound care policies, we now have deeper direct relations with 50+ PDAC and DMEMAC staffers and medical directors who know our work and appreciate our credibility and objectivity.

Q1 Submitted Comments: Ensuring Alliance's Clinical Expert Perspective is Heard

CMS Hospital Harm Measures

The Alliance expressed its concern about CMS' Hospital Harm - Hospital-Acquired Condition - Pressure Injury measure. While the Alliance encourages development of quality measures that assess wound care outcomes, we noted that with the inaccurate information throughout the document, the intended objective will not be achieved the way this measure was crafted. The Alliance requested that the measure be withdrawn and that relevant stakeholders be convened to devise a more clinically meaningful measure.

Key Q1 Meetings & In-Person Advocacy

Alliance Q1 meetings with stakeholders included: 

• Alliance work groups on NPWT/dNPWT and CTP Quality Measuresconvened via conference calls on March 2 and March 8 respectively. These were the first of what will be a series of calls on these subjects and will include am in-person meeting SAWC meeting on April 27 from 12:00-2:00pm.
• HCPCS Coding Reform Meeting with CMS:Together with members of the Alliance of HCPCS Coding Reform, Alliance staff met with senior CMS staff on Jan. 29. Marcia Nusgart reported that the meeting went well and CMS asked many clarifying questions about our coding reform recommendations. CMS asked for additional information that the Agency should use on language in denial letters and alternative requirements for the 3% volume and marketing language in the HCPCS decision tree and HCPCS coding applications. We will be following up and moving the dialogue with CMS forward.
• Member conferences:Alliance staff attended member's annual conferences to meet with leadership, share our work and learn more about the current priorities of our member organizations.
  • APTA Combined Section Meetings (Feb 21-24)
  • National Quality Forum(March 12-13)
  • Diabetic Limb Salvage(April 5-7)
• UPCOMING - SAWC: Join the Alliance at our in-person meeting at SAWC on Friday, April 27. Also, be suer to look for the Alliance's poster (CR029) at SAWC focused on the economic impact of chronic wounds, gleaned from our research published in Value in Health.
• Flagging relevant meetings for members: The Alliance shared information about the following Q1 meetings:
  • CMS webinar on "MACRA Patient Relationship Categories and Codes" held on Feb. 21. 
  • CMS conference call on "Home Health, Hospice and DME Open Door Forum" held Feb. 28.
  • Duke Margolis Center for Health Policy- "Evaluating Inclusion and Exclusion Criteria in Clinical Trials" held April 16. 

Recent Publications & Policies Relevant to Alliance

• HCPCS public meetings: CMS released dates of HCPCS public meetings for 2018: May 14-17 for Drugs/Biologicals/Radiopharmaceuticals/Radiologic Imaging Agents; June 5-6 for Durable Medical Equipment and Accessories/Orthotics and Prosthetics/Supplies/Other.
• PDAC updates: The PDAC announced system to more easily identify the most recent updates on the Product Classification List. It is launching a monthly report with all product additions and updates made. 
• DMEMAC clarification: In a Nov. 2017 webinar hosted by Noridian, the DMEMAC provided information on the surgical dressing LCD that conflicted with the clarification provided to the Alliance via letter in October. The Alliance quickly requested clarification and was again effective in obtaining it: Noridian sent two emails this quarter to webinar participants clarifying misinformation given in webinar on both collagen dressings and foam dressings.
• Outpatient Therapy Cap Repeal and KX Modifier Use: In February, Congress passed the Bipartisan Budget Act of 2018. This legislation contains provisions that extend certain Medicare Fee for Service (FFS) policies; one permanently repeals the outpatient therapy caps beginning on Jan. 1, 2018.  
• ACFAS announces former Alliance board-member Dr. John Steinburg as incoming President of the American College of Foot and Ankle Surgeons.
• Ostomy Wound Management featured an article in its April issue focused on the Alliance's 2017 advocacy and successes.
• Wound Source featured a guest blog post by Marcia Nusgart on the Value in Health study/economic impacts of chronic wounds study.
• The Diabetic Limb Salvage conference (April 5-7) included a poster focused on the economic impact of chronic wounds and other data pulled from the Alliance's recent study.

The Alliance of Wound Care Stakeholders is an association of physician and clinical organizations focused on promoting quality care and access to procedures and technologies for patients with wounds through advocacy and educational outreach in the regulatory, legislative and public arenas. The Alliance unites leading wound care experts to advocate on public policy issues that may create barriers to patients' access to treatments or care, with a focus on reimbursement, wound care research and wound care quality measures.