Whack-a-Mole and the Best Value for Money Ever

If you want to know where to find the best value for money ever, check out the Alliance of Woundcare Stakeholder’s newsletter. I’ve listed below only a few of the issues that the Alliance has reviewed and in most cases, on which it has submitted thoughtful comment letters. It’s a giant game of Whack-a-mole and every year we get farther behind.

It normally costs about $30,000 for a knowledgeable DC law firm to help an organization write a comment letter on draft policy. For the past 18 months, the Alliance has been churning out comment letters at a staggering rate in response to a tidal wave of draft policies.

I am sure it’s hard for manufacturers to draw a direct line from the arcane language in (for example) a regional LCD, to a decrease in sales, particularly if the impact is only going to be noticed after providers get audited. But, the fact is, regulatory and coverage policy are the life-blood of any company in the wound care space, so you would think that when it comes time to allocate budget dollars, advocacy would be second only to R&D.

The Alliance is the forum where all the disparate clinical and non-clinical associations collaborate to speak with one voice. Even when individual Alliance member organizations have their own knowledgeable policy experts, membership in the Alliance allows one organization’s small voice to be magnified. Together Alliance members become a megaphone for issues about which any one organization would have difficulty being heard. Virtually all the clinical aspects of wound care are well represented in the Alliance membership.

If you are a business entity and not a member of the Alliance, you are missing out. We need your support to ensure we can continue to submit comments on all the relevant policies. However, you need the Alliance to help ensure your innovative products get to market and that patients have access to them. The value proposition is explained in more detail on the Alliance website.

I look at this list and I see the looming prospect of Medicare patients who can’t get access to wound care services, and wound care practitioners who decide it’s just not worth it anymore. I know that in a few days, another little draft policy mole is going to pop up its head, and we are going to have to whack it with a comment letter. It would be nice to play offense with data and more research — like the Alliance did with the Value in Health paper on the cost of chronic wounds. But, it’s all we can do to play defense these days.

The Alliance website is an excellent place to find comment letters and pending legislation. If you have a unique area of expertise in any of these areas, check out the list of Alliance member organizations and let the organization to which you belong know that you might be able to help in a specific way, or just email me and we will figure out how we can use your skills as we work on the next draft policy.  Because there will always be a next one.

  • PDAC surgical dressing policy
  • WPS demands repayment for HBOT
  • Medicare physician fee schedule draft language
  • Hospital inpatient PPS
  • Skilled Nursing PPS
  • ESRD DME
  • Palmetto Ask the contractors
  • MedPAC
  • GAO
  • Stark laws