Wound Care Advocacy and Health Policy: Update from the Alliance of Wound Care Stakeholders

To put it mildly, 2017 was a whirlwind year. Even practitioners in the wound care space have felt its impacts. There were important changes at the top of key agencies that involve the policy interests and needs of the wound care community; these changes included a new — then replaced — head of Health and Human Services (HHS) and new heads of the Food and Drug Administration and Centers for Medicare and Medicaid Services (CMS). This was a year that demonstrated that having a united and visible voice in today’s hyperpartisan world is essential.

Throughout the year, the Alliance of Wound Care Stakeholders united wound care clinicians to advocate on public policy issues that could create barriers to patient care and access to treatments/services. Representing 20+ medical societies whose members treat patients with wounds, the Alliance went on the record 17 times this year with 6 comments to CMS, 9 to CMS contractors that set local coverage policies, 1 letter to Congress, and 1 to the HHS Secretary. 

The Alliance sponsored the first comprehensive study documenting the economic impact of chronic wounds to the Medicare program. Findings showed chronic wounds impact nearly 15% of Medicare beneficiaries (8.2 million) at an annual cost to Medicare conservatively estimated at $28.1 to $31.7 billion. This illuminates the need for more wound-relevant quality measures, payment models, and federal research funding. “An Economic Evaluation of the Impact, Cost and Medicare Policy Implications of Chronic Nonhealing Wounds” is available  online in Value in Health. The Alliance has been actively sharing these data and its implications. We’ve placed easy-to-digest fact sheets on our website for those who are interested in a deeper dive or interested in including these findings in presentations and talks. 

The Alliance is advocating for clinically sound, evidence-based coverage policies. Most Medicare coverage of products and services is guided by the local coverage determinations (LCDs) of Medicare Administrative Contractors (MACs). Problematic or overly restrictive LCDs directly impact the products, services, and technologies health professionals can provide to Medicare patients. The Alliance regularly comments on LCDs relevant to wound care. In 2017, we focused on: 

• Protecting negative pressure wound therapy (NPWT). Two (2) draft LCDs proposed eliminating coverage of disposable NPWT (dNPWT). The Alliance sprung in to action, testifying and commenting. We achieved a win for patients and providers: the final Novitas policy, published in September, included coverage for dNPWT plus more flexibility in performing NPWT.

• Defending surgical dressings. A final surgical dressing LCD published in June contained significant areas of concern, including strict frequency limitations on all dressings and ambiguous utilization criteria. With tenacious advocacy toward both CMS senior staff and the MACs, the Alliance requested and obtained a clarification letter to demystify several of the key issues that were causing the most confusion in clinical practice and impacting patient access to products and services. 

The Alliance is elevating the importance of wound-relevant quality measures. Wound care has been largely ignored in the CMS quality measure development process. No wound care-relevant measures are noted in the Merit-Based Incentive Payment System (MIPS), a core part of value-based care initiatives. With payments increasingly tied to measures, this is a major concern in the wound care space. The Alliance has proactively elevated this issue and proposed detailed recommendations, most recently in our comments to CMS’ CY2018 Quality Payment Program and Physician Fee Schedule.

The Alliance is driving research and R&D investments in wound care. The Alliance believes problems with the CMS Healthcare Common Procedure Coding System (HCPCS) — the system used to assign product billing codes — have created barriers to coverage and reimbursement for new technologies in the wound care space. The current process leaves clinicians, manufacturers, payers, and patients with a coding system that inadequately describes the products that are provided and billed. This has had a chilling effect on innovation that drives R&D investments. The Alliance has been pursuing reform of the HCPCS Level II Coding Process and has made strides in 2017 through a series of in-person meetings with CMS staff and leadership to elevate the issue. These dialogues will continue moving forward. 

In 2017, the Alliance celebrated its 15th anniversary of serving as a respected, effective resource on wound care issues for policy makers. Keep up with Alliance advocacy in 2018 at www.WoundCareStakeholders.org. 

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