AAWC Healthcare Public Policy Committee: What Your Team is Doing for You
Eric Lullove, DPM, CWS, FACCWS; and Peg Dotson, RN, BS
The AAWC is involved in many activities that support you and the Association, often accomplished through organized task forces, specialty projects, and ongoing committees. One such committee is the Healthcare Public Policy Committee (HPPC), comprised of dedicated volunteers representing physicians, podiatrists, nurse practitioners, physical therapists, and nurses, along with industry reimbursement specialists.
Our mission for the AAWC is to identify issues that may impact you and your patients concerning product coverage, product access, and payment for products or to providers. The HPPC prepares the AAWC responses to government or private insurers when new regulations or coverage decisions are detrimental to patients and providers. To do this, the team has the daunting task of reviewing the Centers for Medicare and Medicaid Services (CMS) Proposed Rules, issued annually between April and July. These regulations contain the next year’s rules for payment and coverage. Once each Proposed Rule is released, the AAWC has the opportunity to send feedback via comment letters to the CMS. Later in the August-October timeframe, all rules are re-released with updates — the rules may have changed, which requires a second review to ensure the issues AAWC addressed in prior versions have been accepted; if not, a second comment letter is sent before the Rules are finalized.
The HPPC also deals with eQM regulations, new United States Food and Drug Administration guidelines and reviews, Medicare Payment Advisory Panel issues, and revised Local Coverage Determinations coverage policies generated by the 15 Medicare Administrative Contractors (MACs) and the 4 durable medical equipment (DME)-MACs throughout the year. At times, we also tackle state legislation issues. Our partnership and involvement in the Alliance of Wound Care Stakeholders provides us the opportunity to address broad issues and develop comments in unison for the whole wound care clinical industry. Medicare/Medicaid issues by far demand the most time; collectively, they provide medical insurance coverage for more than 125 million people and growing.
To give some perspective, our committee had to evaluate, identify issues and concerns, and prepare comments for the AAWC to respond to the CMS for:
• Skilled Nursing Facility Prospective Payment System (PPS), issued April 27;
• Acute Hospital & Long Term Care Hospitals’ PPS, issued June 5;
• Physician Fee Schedule, issued July 12;
• Hospital Outpatient and Ambulatory Surgery Center PPS, issued July 26; and
• Home Health PPS, issued July 12.
Important this year were the massive changes the CMS proposed to the Physician Fee Schedule Rule regarding how clinicians are to be paid for their services in 2019 and beyond. If the Rule is not amended, the impact could be devastating to physicians, podiatrists, nurse practitioners, and physician assistants. The AAWC’s voice was loud and clear, not only in our comment letter to the CMS, but also in our support for letters generated by the American Podiatric Medicine Association, our support for a multimedical society/association letter signed by key Senators sent to the CMS, and our input into the Alliance joint letter to the CMS for wound care specialty associations/societies. During the same timeframe, private insurer United Healthcare (UHC) issued a problematic coverage policy that severely limited the choices of cellular and/or tissue-based products (CTPs) clinicians would be able to use for chronic wounds. The AAWC participated with the Alliance in preparing and submitting comments to UHC to request changes to this policy.
These collaborations are critical in presenting a unified voice to the CMS and private insurers to ensure patients have, and will continue to have, access to the most appropriate care and providers. Working together in this way reinforces the importance of the AAWC as a multiprofessional wound care specialists’ organization that can bring input to lawmakers, regulators, and insurers.
The AAWC always is striving to work for you and the association so the patients you serve receive the best possible quality and evidence-based wound care.