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Advocacy Update from the Alliance of Wound Care Stakeholders
Celebrating its 15th anniversary in 2017, the Alliance of Wound Care Stakeholders is an association of 21 medical specialty societies, organizations, and provider groups with a focus on promoting quality care and access to products and services for patients with wounds and the providers who treat them. Over its history, the Alliance has united wound care clinicians to advocate on regulatory and legislative public policy issues such as coding, coverage, and reimbursement that can create barriers to patient access to treatment or care. The Alliance also advocates for the establishment and use of appropriate quality measures for wound care.
With the ongoing shifts in the United States health care landscape, having a united voice to represent the wound care perspective in policies and regulations has never been more important. This past year, the Alliance submitted 21 sets of written and oral comments including 11 to the Centers for Medicare and Medicaid Services (CMS), 3 to CMS contractors, 6 to the US Food and Drug Administration (FDA), and 1 to the Agency for Healthcare Research and Quality.
The Alliance elevated the visibility of wound care issues to the CMS as the Agency established quality measures and other regulations that guide implementation of Medicare payment reform and the Medicare Access and CHIP Reauthorization Act (MACRA). The Alliance emphasized to the CMS that the value-based payment models being put in place for clinicians (eg, the Merit Based Incentive Program System) do not adequately take into consideration the specialists/subspecialists who practice wound care, so the obligatory reporting of quality, resource use, and clinical performance measures will not capture a wound care clinician’s outcomes or resource use, negatively impacting their reimbursement under this system.
The Alliance proactively advocates policy makers to add specific wound care quality measures within MACRA reporting requirements. The Alliance has ensured the CMS heard and considered the impact of the evolving value-based care payment reform policies on wound care practitioners.
The Alliance protected patient and provider access to antimicrobial wound care dressings. Due to concerns about antibiotic resistance, the FDA was considering a more rigorous classification/category for these products, a change that could have a significant impact on the cost of product development, availability, and price. As such, the Alliance mobilized clinicians, clinical organizations, and scientists concerned with antibiotic resistance to speak to the use and value of these products. The Alliance educated the FDA on the long-term safety and utility of these products and clarified antimicrobial wound dressings are antiseptics, not antibiotics; they do not contribute to antibiotic resistance. The advisory panel, convened by the FDA to address this issue, ultimately concurred with the Alliance in its classification recommendations (“Class II with special controls”) to the FDA.
The Alliance ensured wound care concerns were flagged to the CMS as it set payment rates in its 2017 prospective payment systems (PPS) for Hospital Outpatient Services and Home Health. The PPS sets fixed payment amounts health systems are paid for certain services for people with Medicare. The Alliance flagged challenges the 2017 regulations present for wound care, noting new problematic payment rates for home health agencies as they provide disposable negative pressure wound therapy (NPWT) products for home use, inaccuracies in coding for certain wound products, and concerns about the required quality measures. The Alliance emphasized to the CMS that the majority of the costs for the care of nonhealing wounds occurs in the outpatient setting where many resource-intensive therapies are utilized (eg, cellular and/or tissue based products for wounds [CTPs], hyperbaric oxygen therapy [HBOT], debridements, NPWT, and home nursing services). Yet, there are no measures specific to wound care or wound clinics in the Hospital Outpatient Quality Reporting program.
The Alliance pursued clinically sound local coverage determinations (LCDs) via advocacy with CMS contractors that set and administer Medicare benefits regionally. If based on outdated or incorrect information, LCDs can block patient and provider access to wound care products and services for Medicare patients. Over the past year, the Alliance flagged concerning provisions on LCDs addressing HBOT, pneumatic compression, CTPs, and NPWT.
Through our proactive advocacy, the Alliance serves as a respected, effective communicator and resource on wound care issues for government agencies and policy makers. The Alliance will continue to bring the wound care clinician’s voice to health and public policy issues. Keep up with the Alliance’s ongoing activities at www.WoundCareStakeholders.org.
For an update on the Alliance of Wound Care Stakeholders’ recent endeavors, please visit https://campaign.r20.constantcontact.com/render?m=1124320051551&ca=b0226295-7b2e-46a9-98e5-a1a4107fe192
