APWCA News

APWCA collaborated with the Alliance of Wound Care Stakeholders to submit comments to the Centers for Medicare and Medicaid Services (CMS) that requested the following waivers be initiated during the COVID-19 Public Health Emergency:

• Relax documentation needed for advanced wound products prior to initiation of these therapies
• Relax the definition of a “qualifying wound” as it pertains to coverage for Surgical Dressings
• Allow an overlap of coverage within the two separate benefits of Part A and Part B
• Allow reimbursement for DME Removable Cast Walkers (HCPCS L4361 and L4387) for patients with diabetic foot ulcers when other methods of offloading are not feasible

APWCA collaborated with the Alliance of Wound Care Stakeholders to submit comments to the Centers for Medicare and Medicaid Services (CMS) that supported the following COVID-19 provisions:

• Reimbursement for telehealth at the non-facility rate, as appropriate, when submitted with a 95 modifier and the place of service corresponding to where that service would have been provided had the service been rendered in person
• Expansion of telehealth services generally
• Choice of medical decision making or total time when determining the level of office/outpatient E/M furnished via telehealth
• Ability to provide virtual check-ins, telephone E/Ms, and e-visits to both new and established patients;
• Ability to provide direct supervision via real time interactive audio and video technology; and
• Coverage and payment for telephone evaluation and management services

APWCA representation participated in a Noridian Healthcare Solutions Contractor Advisory Committee meeting regarding development of their “Wound Care and Skin Substitutes” Local Coverage Determination / Local Coverage Article. Noridian does not currently have an active “Wound Care and Skin Substitutes” Local Coverage Determination / Local Coverage Article, and APWCA was present at this meeting to protect the interests of our members and our patients as these policies are developed. Noridian Part B administers Medicare services in California, Nevada, Oregon, Washington, Idaho, Utah, Arizona, Montana, Wyoming, North Dakota, South Dakota, Alaska, and Hawaii.

APWCA Members Minute with Elizabeth Faust

Over the last month, your APWCA leaders have collaborated with the Alliance of Wound Stakeholders and other organizations on communication with the Centers for Medicare and Medicaid Services (CMS) regarding payment methodology for cellular and/or tissue based products for wounds (CTPs) provided in Hospital Outpatient Departments and Ambulatory Surgery Centers. CMS has expressed an interest in changing the current bundled payment mythology for these services and our communication has focused on protecting the interests of our members and our patients.

The APWCA contributed to a successful effort to reverse a dangerous policy that limited ulcer debridements. Wisconsin Physician Services (WPS) is a Medicare Contractor responsible for six states. They released a Local Coverage Determination (LCD) for ulcer debridement that did not include stage II pressure ulcers or diabetic foot ulcers in its list of covered conditions. The APWCA is a proud member of the Alliance of Wound Care Stakeholders and contributed to their fight against this policy. After many letters and in-person testimony, WPS revised this LCD to include stage II pressure ulcers and diabetic foot ulcers in the list of covered conditions. Advocacy for both you and your patients is part of your APWCA member benefits!

Your APWCA recently collaborated with the Alliance of Wound Care Stakeholders and others in an effort to combat an unfair policy from WPS Government Health Administrators. WPS is the Part B Medicare Administrative Contractor (MAC) for Nebraska, Kansas, Iowa, Missouri, Michigan, and Indiana. WPS released the Local Coverage Article, "A55909: Wound Care Coding Companion for Wound Care L37228”. This article excluded coverage for CPT 97597 (Debridement (eg, high pressure waterjet with/without suction, sharp selective debridement with scissors, scalpel and forceps), open wound, (eg, fibrin, devitalized epidermis and/or dermis, exudate, debris, biofilm), including topical application(s), wound assessment, use of a whirlpool, when performed and instruction(s) for ongoing care, per session, total wound(s) surface area; first 20 sq cm or less) when the depth of the ulcer debrided is limited to breakdown of skin. A letter was written to WPS challenging this exclusion and requesting that WPS provide peer-reviewed literature that supports this exclusion.

APWCA contributed to the effort by the Alliance of Would Care Stakeholders over the last couple months to oppose Noridian’s new policy article governing use of skin substitutes. This article dictates coverage in the absence of a Local Coverage Determination and limits the indication of skin substitute use.

See the full article here.

This year APWCA contributed to the effort by the Alliance of Wound Care Stakeholders to oppose United Healthcare’s policy which limits the use of skin substitute products.

See the full article and read United Healthcare’s Response here.

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