Advocating for the Wound Care Community

Complex coverage and payment regulations dictate which products and services wound care clinicians can provide to their patients receiving Medicare. Yet the Center for Medicare and Medicaid Services’ (CMS) policies can be out of sync with clinical evidence and best practices. These are challenges the Alliance of Wound Care Stakeholders (www.woundcarestakeholders.org) has tackled since its founding in 2002, advocating for the wound care sector and keeping its members informed of coverage and payment policies. 

Without question, 2020 was a year like no other. There were threats to close wound care clinics in response to coronavirus disease-19 (COVID-19) demands on resources, expanded opportunities for wound care coverage in telehealth and nontraditional settings, and changes stemming from the 21st Century Cures Act. Throughout, by leveraging the expertise of its members—medical specialty societies, clinical organizations, and manufacturers—the Alliance educated and advocated payers, regulators, policymakers, and legislators to ensure that evidence-based policies were put in place and access to wound care products/services was protected. 

In March 2020, the Alliance organized a campaign to ensure that wound care was understood as “essential,” providing support to wound care providers as they sought to keep clinics open. During the rapidly evolving policymaking, the Alliance advocated for regulatory flexibilities to remove barriers so that wound care could be provided efficiently, effectively, and safely across a range of sites of service with appropriate reimbursement. For example, the Alliance pursued reimbursement for wound care–related telehealth visits and flexibility in documentation requirements; it also launched an online COVID-19 action center to keep practitioners aware of new policies and flexibilities.

Expanding coverage of surgical dressings. In October 2020, CMS’ Durable Medical Equipment Medicare Administrative Contractors (DME MACs) updated the surgical dressings’ policy to include coverage for secondary and primary use of alginate and other fiber gelling dressings. DME MACs are the Medicare contractors that process durable medical equipment claims and set the coverage policies that can have a huge impact on access to and use of wound care products. Before this update, these dressings could only be billed under Medicare as primary dressings, limiting providers’ discretion and choice. This update was a result of the Alliance’s advocacy that included educating the DME MAC medical directors about how these types of dressings are used, assembling clinical evidence, and submitting policy language for consideration. The end result: an updated policy that allows expanded indications and greater access to fiber gelling dressings. 

Coverage of disposable negative pressure wound therapy (dNPWT) in nursing facilities. Due to the pandemic, many patients were unable to receive wound care treatments in hospitals or physician offices. This prompted the Alliance to review Medicare payment policies for physicians in other sites of service and respond to several issues. In June, the Alliance submitted a letter to 3 Medicare Administrative Contractors (MACs) requesting revised payment policies for dNPWT and other wound care services provided in the home, assisted living, and nursing facilities. As result, one of the MACs announced that it would cover dNPWT in nursing facilities at the applicable Medicare physician nonfacility rate. The Alliance continues to work with other MACs on this issue. 

Persistent advocacy, long-term changes. Not all advocacy has immediate results. Many advocacy “wins” are incremental. Educating policymakers and influencing policy change can take years of submitting comments and voicing needs. The Alliance identifies and leverages multiple opportunities for advocacy to ensure that regulatory agencies are aware of impacts to wound care as policies are crafted. Even recommendations that are not reflected in final policies are important, putting a wound care perspective “on the record” and opening doors for advocacy and dialogue.

A new year. The year 2021 brings a new Administration and Congress, which means new staff members overseeing a broad range of health care initiatives. The Alliance will be proactive and has already begun work providing input on “Cures 2.0” legislation to update the 21st Century Cures Act. As the pandemic is controlled, there will be many policy discussions about which regulatory flexibilities to continue after public health emergency policies expire. The Alliance has already met with the new CMS Technology Coding & Pricing Group as well as the Agency’s Coverage & Analysis senior staff. A voice representing wound care will be imperative, and the Alliance will continue to provide it. 

Marcia Nusgart is the Executive Director of the Alliance of Wound Care Stakeholders. She may be reached at marcia@woundcarestakeholders.org.
 

The opinions and statements expressed herein are specific to the author and not necessarily those of Wound Management & Prevention or HMP Global.
 

This article was not subject to the Wound Management & Prevention peer-review process.