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  • 06/04/2019 7:00 AM | Deleted user

    Last year, on behalf of its members, the APWCA submitted a comment letter to CMS regarding the 2019 Medicare Part B Physician Fee Schedule. A copy of the full letter is attached below.

    The APWCA argued against:

    • Consolidation of payment for levels 2-5 office and other outpatient E/M services
    • New E/M codes for “podiatry services”
    • The application of the MPPR concept to E/M coding
    • The raise to 30 of the score needed to avoid a MIPS penalty
    • Change to the small practice MIPS bonus

    The APWCA commented on some specific RVUs and responded to their request for information regarding postoperative visits following 10 day global procedures.

    Final APWCA 19 MPFS Comment Letter.pdf

  • 06/03/2019 7:00 AM | Deleted user

    The APWCA contributed to the comments recently contributed by the Alliance of Wound Care Stakeholders to the Physician- Focused Payment Model Technical Advisory Committee (PTAC) regarding a proposal regarding “Bundled Payment for All Inclusive Outpatient Wound Care Services in Non Hospital Based Setting” that was submitted by Seha Medical. The comment letter expressed concern regarding one all-inclusive payment as it would negatively affect the care that providers would be able to deliver. The fear that one all-inclusive payment could also limit the care that patients receive was shared. The letter pointed out that the proposal did not require the provider to adhere to a particular care model, follow a particular set of national guidelines or established protocols in order to achieve the desired cost and utilization objectives. Furthermore, the point was made that chronic ulcer patients often have multiple co-morbidities requiring treatment to optimize ulcer care, and this proposal did not account for that. The Alliance letter concluded with a request to not implement the proposal as written and an offer to serve as a resource to the PTAC if it wants to consider a bundled payment for wound care services.

  • 05/08/2019 9:22 AM | Deleted user

    Last year, on behalf of its members, the APWCA submitted comments to CMS regarding the electronic clinical quality measure titled, “Hospital Harm – Hospital- Acquired Pressure Injury.” We expressed concern that the denominator had no exclusions and suggested that certain exclusions be included. A cope of that letter is below:

    The American Professional Wound Care Association® (APWCA) is a non-profit medical association welcoming medical providers from all disciplines involved in prevention and treatment of difficult wounds. Through a synergy of disciplines, APWCA has been a worldwide leader in clinician advocacy and education for the prevention and treatment of acute and chronic wounds since 2001. This association provides an informational and educational forum for healthcare providers, while promoting excellence in wound healing and patient advocacy.

    On behalf of the APWCA we appreciate the opportunity to comment on the electronic clinical quality measure titled, “Hospital Harm – Hospital- Acquired Pressure Injury.” We are concerned that the denominator has no exclusions. All hospitalized patients ages 18 years and older are included. We agree that pressure ulcers should be avoided in all patients when possible, but contend that all pressure injuries are not preventable. We agree with your statement in question #7 that “practices may change for end- of-life or hospice patients who have a comfort care-only order.” Comfort care-only orders can be captured in some EHR systems, but not all. There are also some hospitals still not using a fully functional EHR. Therefore, we do suggest denominator exclusions in this measure.

    We suggest that the following exclusions be considered:
    Palliative care
    End of life care
    Metastatic malignancies
    Septic shock

    As you know, the same critical pathologies that compromise perfusion to critical organs such as the heart, lungs, and brain also compromise perfusion to the skin!

    Thank you for the opportunity to provide this feedback and for considering our suggestion

    Robert Skerker, MD, FAPWCA
    Medical Director, Morristown Wound Healing Center
    APWCA liaison to the Alliance of Wound Care Stakeholders

    Jeffrey D Lehrman, DPM, FASPS, MAPWCA
    Medical Director, Center for Wound Healing and Hyperbaric Medicine at
    Crozer-Chester Medical Center
    APWCA Board of Directors

  • 03/15/2019 4:41 PM | Deleted user

    NEW THIS YEAR! Special APWCA discounted rate of $299 (Enter code: APWCA-2019) to attend the 20th Anniversary NCVH 2019 Annual Conference, which now includes a day-long educational track focused on the interdisciplinary integrated team approach to wound care - Save hundreds of dollars!

    Register Here!

    APWCA will be presenting a full day didactic session on May 31st! See schedule of the day below:

    10:00 - 11:20AM NCVH/APWCA Session IV: Reconstruction of Complex Tissue Defects in the Lower Extremities
    10:00 - 10:10AM The Importance and Goals of Wound Healing in Limb Preservations, Charles Andersen, MD
    10:10 - 10:20AM When to get a Vascular Consult and the Limitation of Non-Invasive Vascular Studies, Craig Walker, MD
    10:20 - 10:30AM Identifying the Etiology of the Wound, Charles Andersen, MD
    10:30 - 10:40AM Debridement of the Complex Wound: Extent, Tools and Frequency Stephanie Wu, DPM
    10:40 - 10:50AM Controlling the Bacteria in the Wound: Topical vs. Systemic Treatment, Charles Southerland, DPM
    10:50 - 11:00AM Venous Ablation for the Venous Leg Ulcers: Indications and Timing, Robert Coronado, MD
    11:00 - 11:10AM THat is the Role of Cellular and or Tissue Based Products in Dermal Reconstruction: Evidence Based Medicine, Steven Kavros, DPM

    11:20 - 1:30PM Lunch/Lunch Symposia/Exhibits

    1:30 - 3:00PM [Podiatry and Wound Care] Session V: Reconstruction of Complex Tissue Defects in the Lower Extremities
    1:30 - 1:40PM Hyperbaric Oxygen Therapy: What is the Evidence? Jeffrey Niezgoda, MD
    1:40 - 1:50PM Vascular Imaging: Evidence to Improve Outcomes, Jeffrey Ross, DPM, MD
    1:50 - 2:00PM When to Consider Flaps vs. Split Thickness Skin Grafts, Charles Southerland, DPM
    2:00 - 2:10PM Taking the Mystery Out of Offloading: It is more than a Simple Insert, Steven Kavros, DPM
    2:10 - 2:20PM Compression Therapy for Chronic Venous Insufficiency: Compression Wraps vs. Gradient Support Hose, Cheryl Bongiovanni, PhD
    2:20 - 2:30PM Topical Oxygen: Hocus or Evidence Based, Stephanie Wu, DPM
    2:30 - 2:40PM What is Feasible for Complex Would Healing in the Changing Economic and Reimbursement Environment, Steven Kavros, DPM
    2:40 - 2:50PM Questions and Answers/Panel Discussion
    2:50 - 3:00PM Closing Remarks, Frank Tursi, DPM 

    3:00PM Adjourn

  • 06/12/2018 9:45 AM | Deleted user

    Recent research demonstrates the effectiveness of various foam dressings for pressure redistribution. Jeffrey Niezgoda, MD (APWCA Vice-President) recently published his findings in a poster presentation (SAWC 2018).  His results demonstrated that all foams are not equivalent in the ability to provide pressure relief in patients at risk for developing pressure ulcers.  OxyBand Rescue out performed all other foam dressings currently on the market, providing superior reduction in average pressures and peak pressures, while at the same time maximizing contact area.  The NPUAP has recently published recommendations advocating the use of foam dressings to provide pressure redistribution in an attempt to reduce the risk of pressure ulcer formation in at risk patients.  A copy of the Poster is provided.  

  • 02/23/2018 1:17 PM | Anonymous

    The Centers for Medicare and Medicaid Services (CMS) recently released an announcement seeking input from stakeholders on a new electronic clinical quality measure under development titled, “Hospital Harm – Hospital-Acquired Pressure Injury.”

    This measure assesses the proportion of hospitalized patients 18 years and older who develop a new stage 2-4 pressure ulcer, deep tissue injury, unstageable pressure ulcer, or experience worsening of any of the above during their hospitalization.

    We read the full description of the measure and provided the following feedback on behalf of APWCA membership:

      • Concern that the denominator has no exclusions; made the point all pressure ulcers are not preventable
      • Responded to one of the questions posed by the measure authors by explaining protocols may change for end-of-life or hospice patients who have comfort care-only orders
        -- Clarified this could be difficult to track because comfort care-only orders may not be captured in some EHR systems and some hospitals are still not using a fully functional EHR
        • Suggested denominator exclusions be added to this measure, including:
        -- Palliative care
        -- End-of-life care
        -- Metastatic malignancies
        -- Septic shock

        This is just one example of how APWCA advocates for our members.  To learn more about your membership and benefits visit www.apwca.org.

        If you would like to submit comments on your own, follow these instructions provided by the Alliance of Wound Care Stakeholders:

                      1. Select “Projects” at top middle on home screen
                      2. Select “View All Projects”
                      3. Select “Quality-Measures” on left-side of screen
                      4. Select “Comments on eCQMs under development” project
                      5. To enter comments, select “Create” (orange button) at the top middle of the screen
                      6. Select the type of issue from the “Issue Type” drop-down menu
                      7. In “Summary” field, type the following title: 
                          Hospital Harm – Hospital Acquired Pressure Injury
                      8. Select the measure name for comment on from the “Draft Measures” drop-down: 
                          Hospital Harm – Hospital Acquired Pressure Injury
                      9. Fill out fields labeled “Contact name,” “Contact email,” and “Contact phone”
                    10. Enter comments in the “Description ”field or upload an attachment under the “attachment” field
                    11. Select “Create” at the bottom left to submit comments
                    12. For additional comments, select “Create another” and then “Create”

      • 02/06/2018 11:28 AM | Anonymous

        Immediate Medicare Changes That May Affect You

        The Medicare Administrative Contractor (MAC) for Jurisdiction J (Tennessee, Alabama, and Georgia) is transitioning from Cahaba to PalmettoThe Part A transition went into effect January 26, 2018 and Part A providers should already be submitting claims to Palmetto GBA. Cahaba has discontinued the receipt of Part A redetermination, reopening, and ADR submissions via the InSite Web Portal. 

        Any of your Part A Redeterminations, Reopenings or ADR responses should now be sent to:

        Cahaba Medicare Part A
        Post Office Box 6168
        Indianapolis, IN 46206

        If you have been communicating with Cahaba via FAX, you may find that some of those FAX lines are no longer functioning, including some that deal with Part B. If you need to communicate Part B information to Cahaba after January 26, 2018 they ask that you use this mailing address:  

        Cahaba Medicare Part B
        Post Office Box 6169
        Indianapolis, IN  46206

        The Part B transition goes into effect February 26, 2018.  Providers should note that their Local Coverage Determinations (LCDs) will transition from Cahaba to Palmetto. A listing of Palmetto LCDs can be found here: Software vendors should update their software to send claims to:

        Part A:
        Palmetto GBA
        Attn: JJ Medicare Part A PO Box 100305
        Columbia, SC 29202-3305 

        Part B:
        Palmetto GBA
        Attn: JJ Medicare Part B PO Box 100306
        Columbia, SC 29202-3306 

        More information can be found at the Jurisdiction J Transition website:  https://www.palmettogba.com/JJTransition

      • 01/25/2018 9:52 AM | Anonymous
        President, Dr. Steven Kavros, and member, Dr. Robert Coronado have been published in the February issue of Advances in Skin and Wound Care. ‘Diagnostic and Therapeutic Ultrasound on Venous and Arterial Ulcers: A Focused Review’ can be read online now.
      • 11/06/2017 4:27 PM | Anonymous

        In August 2017, the APWCA distributed a survey to its members to collect their perceptions about change in the pressure ulcer staging system as proposed by the National Pressure Ulcer Advisory Panel (NPUAP). The proposed change was centered around the use of the term 'pressure injury' to replace 'pressure ulcer'.

        An invitation email was sent to the APWCA's 1020 members. About 190 members accessed the survey and about 150 responses were submitted. This results in a response rate of 15% and provides a Confidence Interval of ± 7%. The survey consisted of 6 items. Each item and its results are appended in this report.


        • A plurality of respondents (40%) felt that 'pressure ulcer' was the most acceptable term with 30% of respondents deeming both 'ulcer' and 'injury' to be acceptable.
        • A slight majority of respondents (58%) felt that Stage 1 and Deep Tissue Injury (DTI) should be included in the staging system despite the drawback of including lesion that occur in the absence of broken skin
        • A plurality of respondents preferred to keep the term 'stages' (43%) as opposed to 'categories' (28%) in describing the continuum of ulcerations included in the classification scheme.
        • An equal number of respondents felt that pressure ulcer (38%) or both pressure ulcer or injury (37%) were reflective of etiology.
        • A plurality of respondents (43%) felt that a change in terminology should be first addressed by entities charged with nomenclature and policy before changes are implemented. This indicates a desire for a procedural sequence to be undertaken before adopting new terminology.
        • A significant majority of respondents (70%) felt that 'injury' reflects an implication of harm even if it is unintended. This is an important finding as it reflects the fact that some respondents preferring 'injury' and those accepting of both 'ulcer' and 'injury' expressed this concern.


        Taken together, the results indicate that while a plurality of APWCA respondents would prefer to keep the term ulcer, many would be accepting of the term 'injury'. That being said, if a change in terminology is to be pursued, the results indicate that two issues be addressed: 1) the implication of harm associated with the term 'injury' should be addressed and mitigated in some manner and, 2) a terminology change should be first addressed by entities charged with nomenclature and policy.

        View Detailed Responses
      • 11/03/2017 3:35 PM | Anonymous

        The Quality Payment Program (QPP) Final Rule was released last night. We are still reviewing every detail and considering comments to submit, but below you will find some of the big points we have pulled out so far.

        • Threshold to avoid a penalty moves from 3 to 15 MIPS points
        • 2014 and/or 2015 CEHRT allowed but bonus ACI points available if use only 2015 CEHRT
        • Eligible clinicians or groups with <= $90K Part B allowable or <= 200 Part B beneficiaries excluded
        • Cost category counts for 10% of MIPS score
        • Cost category score will be calculated by Medicare Spending per Beneficiary (MSPB) and total per capita cost measures
        • CMS will calculate Cost measure “performance” - nothing for us to report for that category
        • Clinicians affected by Harvey, Irma, or Maria that do not submit 2017 MIPS data will not have a negative adjustment in 2019
        • Clinicians affected by Harvey, Irma, or Maria can file a hardship exception application for Quality, ACI, and CPIA categories for 2018 performance period
        • Still only allowed one submission method per category
        • Quality category moves from 60% of MIPS score in 2017 to 50% in 2018
        • Clinical Practice Improvement Activity category still counts 15% - can still avoid penalty with just a perfect CPIA score
        • Clinicians in practices of 15 or less are exempt from ACI category and that 25% moves to Quality category
        • Exceptional performance threshold remains 70 MIPS points
        • Option to participate as a Virtual Group
        • 2018 QPP Final Rule Reporting Periods: Cost - 12 mos, Quality - 12 mos, ACI - 90 days, CPIA - 90 days
        Links: Full Release / CMS Summary Sheet

        Nothing discussed in this communication guarantees coverage or payment. This is our interpretation of the Final Rule. Coverage and payment policies of governmental and private payers may vary from time to time and in different parts of the country. Questions regarding coverage and payment by a payer should be directed to that payer. APWCA does not claim responsibility for any consequences or liability attributable to the use of any of the information discussed in this communication.

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