There’s a scene in “Men in Black” where Jay panics about a looming crisis, but Kay tells him that there’s always an intergalactic plague threatening to destroy the earth, and that the only way people get on with life is if they don’t know about it. Truthfully, the field of wound care could use a little more panicking. For 15 years, the “MIB” division of Wound Care has done too good a job, so most practitioners don’t know how much work it takes to keep the field from annihilation.
For many years I have been proud to co-chair the Alliance of Wound Care Stakeholders, an association of physician and clinical organizations focused on promoting quality care and access to products and services for patients with wounds and the providers who treat them. The Alliance unites leading wound care experts to advocate on public policy issues that may create barriers to patient access to treatments or care. It’s the MIB of wound care.
In 2017, the Alliance responded to an unprecedented number of legislative and regulatory issues. I’ve attached links to a few of the accomplishments and comment letters that I think are the most relevant to the wound care clinician, but all of the Alliance official comments are available on its website: http://www.woundcarestakeholders.org/
- The Alliance sponsored an analysis of the cost to Medicare of chronic wounds ISPOR’s Value in Health: “An Economic Evaluation of the Impact, Cost and Medicare Policy Implications of Chronic Nonhealing Wounds,” which showed that chronic wounds impact nearly 15% of Medicare beneficiaries (8.2 million) at an annual cost to Medicare conservatively estimated at $31.7 billion per year. Here’s the topline news release and fact sheet.
- Comments to CMS on CY 2018 Updates on the Quality Payment Program regarding how evolving MACRA policies would impact wound care clinicians. Comments supported the use of QCDRs and the ability of all eligible clinicians to use the QCDR option for reporting: comments.
- CY 2018 Physicians Fee Schedule: Alliance submitted comments to the Proposed CY 2018 Physician Fee Schedule updates, addressing a range of issues including evaluation and management services (E/M codes), hyperbaric oxygen therapy, CPT codes for NPWT, and quality measures.
- CY 2018 Hospital Outpatient Prospective Payment System: The Alliance submitted comments to the proposed CY 2018 Hospital Outpatient Prospective Payment System
- DMEMACs and Surgical Dressing issue:
- The Alliance sent another letter to the DMEMACs focusing on clarification issues regarding collagen dressings and wound staging. In October, the DMEMACs responded with a “clarification letter” on these.
- The DMEMAC issued the correct coding article “Correct Coding – HCPCS Coding of Surgical Dressings – Components to Report on the PDAC HCPCS Code.”
- Monitoring & Updates: Alerted members of CMS’s January 1, 2017 OPPS update transmittal includes changes to the high cost/low cost CTP assignments in light of updated data.
- Local Coverage Determinations affecting wound care, cellular products, NPWT:
- Written comments to Novitas on draft LCD on wound care (March)
- Written comments to FCSO draft LCD on wound care (March)
- Written comments to WPS draft wound care LCD (June)
- Written comments to Novitas draft LCD on treatment of varicose veins of the lower extremities (March)
Now you can see why the Alliance deserves to be thought of as the MIB of wound care. As long as I don’t have to deal with roaches. I have a thing about roaches.