With quality measure-based payment models now driving Medicare reimbursement under the Medicare Access and CHIP Reauthorization Act (MACRA), wound care providers have been left with few performance measures to report that are relevant to the care they provide.
The Alliance of Wound Care Stakeholders, an association of 20+ clinician groups and medical specialty societies focused on promoting quality care and access to products and services for wound care patients and the providers who treat them, has been leading advocacy initiatives to educate policy makers and regulators about the importance of more meaningful performance measures and reimbursement models for the wound care space.
The Alliance recently funded research to document the cost of wounds as part of advocacy efforts to bring improved data to the Centers of Medicare and Medicaid Services (CMS) as the agency evolves MACRA and the quality measures that comprise its reimbursement models. The study analyzed the Medicare 5% Limited Data Set for CY2014 and determined that chronic wounds impact nearly 8.2 million — 15% of Medicare beneficiaries. Total Medicare annual spending estimates for all wound types ranged from $28.1 to $96.8 billion, with treatment and management of infected or reopened (dehisced) surgical wounds driving the highest costs, followed by diabetic foot ulcers. The study, soon to be published in the pharmacoeconomics journal Value in Health, also highlights a major shift of wound care costs from the hospital inpatient to outpatient settings.
The documentation of the economic cost of chronic wounds potentially can influence CMS priorities as MACRA implementation evolves and the accompanying Quality Physician Payment regulations are updated.
Additional Alliance Advocacy Efforts
Protecting patient and provider access: driving clinically sound 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 reviews new LCDs, gathers input of and impact on the clinical community, and submits formal comments. In January, 2 MACs (Novitas and First Coast Service Options) released nearly identical and equally problematic LCDs that, in the Alliance’s estimation, had little foundation in medical evidence and/or did not adhere to current clinical practice guidelines. The LCDs negatively impact access to negative pressure wound therapy and debridement services, among other wound care options. The Alliance and clinicians from its member medical societies testified at public meetings and submitted written comments relaying concerns and proposing solutions to ensure the next, final iteration of the LCDs are more clinically sound policies.
Similarly, the Alliance has been proactive in advocacy regarding a recent LCD on surgical dressings. The original draft had published in 2015, at which time the Alliance, its members, and many others in the clinical community voiced concerns and submitted comments. However, the final LCD that went into effect this past July reflected little of the comments submitted by stakeholders and lacked clarity on key issues regarding the prescription and utilization of surgical dressing products. The Alliance currently is requesting that the MACs publish clarifications so the LCD can be more workable in wound care settings moving forward.
Voicing the need for transparency/accountability in coding and coverage policies. The US Congress has recognized that the LCD development process needs improvement. Legislation to improve MAC transparency and accountability was introduced in the US Senate (S 794) and in the House of Representatives (HR 3635) this year. The Alliance is proactively developing strategies to support and strengthen these legislative initiatives, which can impact not just wound care, but the entire health care/Medicare space.
The Alliance also recently joined more than 50+ health care organizations in a joint letter to the CMS and the US Department of Health and Human Services advocating for greater transparency and predictability in the Healthcare Common Procedure Coding System (HCPCS) coding process that sets product, supply, and service billing codes for Medicare, Medicaid, and private health plans.
In 2017, the Alliance of Wound Care Stakeholders marks its 15th anniversary of bringing the wound care clinician’s voice to health and public policy issues. Keep up with the Alliance’s ongoing activities at www.WoundCareStakeholders.org.