CTP Reimbursement: Present Challenges and Future Changes

© 2023 HMP Global. All Rights Reserved.
Any views and opinions expressed are those of the author(s) and/or participants and do not necessarily reflect the views, policy, or position of Today’s Wound Clinic or HMP Global, their employees, and affiliates.

Marcia Nusgart, RPh:
Hi, I'm Marcia Nusgart. I'm the Chief Executive Ocer of the Alliance of Wound Care Stakeholders.
 
Karen Ravitz, JD:
And I'm Karen Ravitz, and I'm the Health Policy Advisor for the Alliance of Wound Care Stakeholders.
 
Marcia Nusgart, RPh:
And the Alliance of Wound Care Stakeholders is the united voice for the wound care industry. And we've been around for now about 21 years. I created it when we realized that we needed to be able to have one voice for wound care, where you have so many different clinical associations whose members treat patients with chronic wounds. And when we go and we're an advocacy association, so when we speak on behalf of the wound care industry to the Centers for Medicare and Medicaid Services or the Food and Drug Administration, they want to be able to have a collective, united voice because we're so much stronger that way. And so we advocate on a number of different wound care issues.
 
And our mission is to be able to ensure that patients will have access to so many of these technologies and treatments who are being treated by these clinical associations in the chronic wound care space. And what we focus on is coverage, coding, and payment, the reimbursement areas, as well as wound care quality measures, wound care research, as well as anything that has to do with wound care. I always joke with those who are heading up the FDA or CMS, and I ask them what's on their desk because that has to deal with wound care because what's on their desk is going to be on Karen's and my desk, and we're going to be working with them.
 
So we are just very lucky and fortunate that we have so many members. We have clinical association members, non-clinical associations, business entities, wound care provider groups, startup businesses as well, and wound care clinics. So we have a wide variety of the wound care industry that work with us on so many of these very, very important issues.
 
What are the recent developments in CMS rules for CTPs?
 
Marcia Nusgart, RPh:
2023 was a banner year for us working on behalf of CTPs, meaning the clinicians that actually do prescribe these products, and the companies who manufacture them. And there's a number of different rules and regulations and coverage policies that really did impact this particular industry.
 
Karen Ravitz, JD:
Also, there were some LCDs that were issued. This was in CGS, Novitas, First Coast. It really, those areas. What's an LCD? A local coverage determination. As well as policy articles.
 
Marcia Nusgart, RPh:
So we were able to score a major victory this year in this particular area. On behalf of the wound care community. And quite frankly, it was a collective effort because these particular LCDs and LCAs were very, very onerous for clinicians in this area, as well as for the companies that manufacture them also. And we had a number of different issues with them.
 
And this was a year where we decided that it was really a call to action. And you can even see on our website that we had asked clinicians as well as their patients to write in to the medical directors of these three Medicare administrative contractors to address how egregious these particular policies were and how they were going to impact patient care. So we did that. And what else did we do, Karen?
 
Karen Ravitz, JD:
We submitted letters. We did town hall meetings. We galvanized clinicians across the country to testify, send in letters. And really, it was very impactful. We also had some legislative visits. We talked to members of Congress. They were getting involved, asking for withdrawal of this policy. It really was so problematic for patients and possible access to care that the community really came together. And thankfully, we were successful. And they did withdraw the policies. For now. So in terms of what's happening moving forward, they all said, each one of those Medicare contractors said that they were going to be issuing policies again very soon. So we're waiting to see what they're going to come up with in the next round of this policy for coverage for CTPs.
 
Marcia Nusgart, RPh:
So we do have a CTP work group that's comprised of clinicians, our clinician members, as well as our business entity members. And right now, we're determining the strategy and how we're going to be working together to be proactive on this particular issue. So we have a number of different things. So stay tuned in that particular area.
 
What's interesting, though, is that while we spent an enormous amount of time on this product sector, just to let you know that we do spend also a lot of time on so many other areas, really, that do impact both clinicians as well as provider groups, business entities, anyone that's involved in wound care. So we have a lymphedema work group. We also have a new technologies work group, a surgical dressings work group that we're working together with our members because of certain edits that CMS has made when you have many of the providers that bill for these products may not have access to these products for their patients.
 
So we're submitting a letter to Medicare and their contractors to be able to help alleviate some of these issues. We also, like we said, CTPs, negative pressure wound therapy. And whenever there is an issue that we need to be able to galvanize our members and put together a work group, we do. We just create a blood-derived products work group, too, and they have a work plan.
 
So we're, as you recall, that movie last year, Everywhere, Every Place, All at Once, I think that was the name of it. That's how it seems to us this past year that we've been working on so many issues on behalf of our members and also for the patients that need all these wonderful, important products.
 
What are some potential changes with CTP payment rules?
 
Karen Ravitz, JD:
CMS is really trying to figure out a way that they can consolidate and have a consistent payment approach for this product across all settings. So it looks like they're looking to bundle in every site of service both the payment for the product as well as the procedure. And that's kind of the direction they're heading. It's just the problem is that each site of service has a different payment methodology and different approaches. So how do you do that when you have a product that has a variety of different products, sizes, costs, et cetera? How do you then sort of figure out how to get a payment methodology then that would support that? And that's kind of what they're struggling with, really.
 
So in the physician payment, so I had just said everything's status quo for now, but what they were trying to do was to create a payment system that was consistent with CMS to create a payment system where the CTPs would be considered incident to supplies and they'd become part of the practice expense in the physician office. And that's just a whole—it's really complicated and it's really difficult for them to figure out how to do that fairly, which is why for the past couple of years they haven't finalized anything and they're still seeking stakeholder feedback.
 
But where are they going? That's what they're trying to do. They're really just trying to figure out a way that they can create a consistent payment approach in a system that doesn't have a consistent payment.