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  • 08/24/2026 1:55 PM | Anonymous


    The New National Fraud Enforcement Division

    What Every Wound Care Provider Should Be Doing Right Now

    B. Moira Sykstus, CHC, CPCO, CPMA, RRT, DAPWCA
    Chief Compliance Officer, Redemption Revenue & Compliance Services

    Quick Read Summary

    The Department of Justice has formally established the National Fraud Enforcement Division, reinforcing a national approach centered on fraud involving taxpayer-funded programs, data-driven investigative techniques, and interagency coordination.

    For wound care providers, the immediate response should be practical: build a functioning compliance program, audit records routinely, monitor billing and utilization data, and strengthen oversight of high-risk services before an outside reviewer identifies the problem.

    • The enforcement environment is increasingly data-driven and coordinated.
    • Debridement, Cellular and Acellular Matrix-like Products (CAMPs), modifier use, medical necessity, wound measurement consistency, and same-day E/M billing deserve focused review.
    • RAC, UPIC, SMRC, MAC, and TPE activity can expose weaknesses in documentation, coding, credentialing, utilization, and internal oversight.
    • Claims payment is not proof of compliance.
    • If your organization does not have a compliance program, start one. If you are not auditing records, start now.

    A Structural Change with Practical Consequences

    The U.S. Department of Justice published a final rule on August 18, 2026, formally establishing the National Fraud Enforcement Division in 28 CFR Part 0, effective August 24, 2026. The rule describes a mission focused on fraud against taxpayer dollars and taxpayer-funded programs, supported by advanced, data-driven investigative techniques and coordination with program agencies and law-enforcement partners.

    The rule does not create new substantive healthcare fraud statutes. Its practical importance is organizational: fraud enforcement is being centralized, authorities are being formally assigned, and data and coordination are central to the Division’s mission.

    For wound care providers, the relevant question is not how the Department of Justice organizes itself. The relevant question is whether the practice can demonstrate that its claims, documentation, product utilization, and clinical decision-making are accurate, medically necessary, and consistent with applicable requirements.

    If You Do Not Have a Compliance Program, Start One

    A compliance program should function as an internal early-warning system, not as a binder placed on a shelf. It should help the organization identify risk, educate clinicians and staff, investigate concerns, implement corrective action, and confirm that corrective action worked.

    • Written compliance standards and policies
    • A designated compliance leader with authority and access to leadership
    • Routine education for clinicians, coders, billers, and operational staff
    • Confidential pathways for reporting concerns
    • Risk-based auditing and monitoring
    • Consistent corrective action and follow-up
    • Documented oversight by practice leadership or the governing body

    Starting Point

    A smaller practice does not need a complicated bureaucracy. It does need clear accountability, written expectations, a reporting pathway, scheduled audits, documented corrective action, and leadership that acts on findings.

    The Hidden Risk: A Compliance Program That Exists Only on Paper

    A compliance program that exists only on paper may create a false sense of security and can increase exposure when written expectations, audit findings, reported concerns, or corrective-action commitments are not carried out.

    Once an organization adopts policies and oversight processes, leadership should be prepared to demonstrate that the program is active: risks are identified, concerns are investigated, corrective action is implemented, and follow-up confirms that the correction worked.

    A policy that is routinely ignored, an audit finding that is not addressed, or a known weakness that repeatedly recurs may raise questions about the effectiveness of organizational oversight and the credibility of the compliance program.

    Typical Compliance Program Failures

    • Policies and procedures are outdated, generic, or inconsistent with current operations.
    • Internal audits identify deficiencies, but findings are not assigned, corrected, or tracked to closure.
    • The same documentation, coding, billing, or utilization issues recur in later reviews.
    • Education is provided without follow-up monitoring to determine whether performance improved.
    • Compliance committee or leadership oversight exists on paper, but meetings, decisions, and follow-up are not documented.
    • Employee complaints, hotline reports, or other concerns are not investigated and resolved promptly.
    • Corrective-action plans are created, but implementation and effectiveness are never verified.
    • High-risk services are recognized, but no risk-based audit or monitoring plan is maintained.
    • Overpayments or potential billing errors are identified, but escalation, evaluation, and resolution are delayed.
    • Compliance responsibility is assigned without sufficient authority, access to leadership, resources, or accountability.

    Compliance Risk Spotlight

    A compliance plan on a shelf creates a false sense of security. The strongest compliance programs are actively used, routinely tested, supported by leadership, and able to demonstrate timely corrective action when risks are identified.

    If You Are Not Auditing Records, Start Now

    Claims can be paid and later reviewed. A clean remittance does not establish that documentation supported the service; the correct code was selected, or all coverage and billing requirements were satisfied.

    Begin with a baseline audit across high-risk services and providers. Review a meaningful sample from recently completed episodes, trace each claim back to the signed medical record, and document the finding, education, correction, and re-audit.

    Wound Care-Specific Audit Priorities

    Medical Necessity and the Wound-Healing Narrative

    The record should explain the wound’s status, clinical barriers to healing, treatment goals, response to prior interventions, and the rationale for the current plan. An independent reviewer should be able to understand why the service was reasonable on that date.

    Debridement Services

    Audit the documented tissue removed, depth, surface area, method, wound findings, clinical rationale, and consistency between the procedure note and the code submitted. Repetitive language should not substitute for patient-specific findings.

    Wound Measurements and Progress

    Review length, width, depth, area when used, wound-bed findings, drainage, tissue characteristics, and serial change. Inconsistent measurement methods, unexplained shifts, and copied-forward values weaken the record.

    Cellular and Acellular Matrix-like Products (CAMPs)

    Confirm patient selection, relevant prior treatment, wound-bed preparation, product choice, size and units, application details, wastage reporting when applicable, response to treatment, and the rationale for each subsequent application.

    The record should explain why a CAMP was selected at that stage of care and how continued use fit the overall plan.

    Evaluation and Management Services with Procedures

    When an E/M service is separately reported on the same date, verify that the documentation supports a distinct, medically necessary service beyond the usual pre- and post-procedure work.

    Modifier Utilization

    Monitor provider-level use of modifiers 25, 24, 59 and related modifiers, repeat-procedure modifiers, and wastage modifiers. Focused review should determine whether the documentation supports the modifier and whether use differs materially among providers.

    DMEPOS and Supply-Related Services

    Where applicable, review orders, medical necessity, supplier obligations, proof of delivery, utilization, beneficiary records, enrollment, and the relationship between the furnishing entity and the treating practice.

    Place of Service, Credentialing, and Billing Entity

    Verify that the rendering provider, billing entity, enrollment status, reassignment, supervision, and place of service are accurate for the date of service.

    Infection, Perfusion, and Contributing Conditions

    Ensure the treatment plan reflects documented infection assessment, perfusion or vascular evaluation when clinically relevant, pressure relief or off-loading, edema management, glycemic issues, nutrition, and other healing barriers.

    RAC and Program-Integrity Audit Targets to Put on Your Work Plan

    Audit topics change by contractor, jurisdiction, setting, and date of service. The following are practical wound care exposure areas for an internal risk assessment, not a statement that every contractor currently lists each item as an active target.

    High-Cost or Repeated CAMP Claims

    Can the record support eligibility, product selection, units, application frequency, wastage, and continued medical necessity for every date?

    Debridement Code Depth and Area

    Does the note support the tissue depth and total surface area represented by the submitted code and add-on units?

    Repeated Services with Limited Documented Progress

    Does the plan change when expected progress is not achieved, and is the clinical reasoning documented?

    Same-Day E/M and Procedure Billing

    Is a significant, separately identifiable E/M service apparent from the record?

    Modifier Outliers

    Can each modifier be supported, and can variation among clinicians be explained?

    Incorrect Entity, Enrollment, or Place of Service

    Were claims submitted under the correct provider and entity, with accurate enrollment and setting information?

    Missing Orders, Signatures, or Certifications

    Are records complete, authenticated, timely, and linked to the billed service?

    Insufficient Conservative-Treatment History

    When an applicable requirement or clinical rationale depends on prior management, does the record state what was provided, for how long, and how the wound responded?

    Product Units and Wastage

    Do product size, wound size, amount applied, amount discarded, HCPCS units, and modifiers reconcile?

    Utilization Above Peers or Rapid Growth

    Can leadership explain growth, patient mix, referral patterns, staffing, outcomes, and controls that expanded with the service line?

    Know Your Data Before Someone Else Reviews It

    The Fraud Division’s formal mission includes advanced, data-driven investigative techniques. Wound care organizations should apply the same discipline internally. A data flag is not proof of misconduct, but it is a reason to validate the underlying claims and records.

    • Peer comparison by specialty, setting, location, diagnosis mix, service mix, and patient population
    • Provider-level analysis of codes, modifiers, units, frequency, allowed amounts, and beneficiaries
    • Longitudinal trend analysis for rapid growth, abrupt coding changes, and new high-volume services
    • Claims-to-record reconciliation for selected dates of service
    • Code-pair and episode analysis for repeated procedures, same-day services, and unusual combinations
    • CAMP product, size, unit, wastage, application-frequency, and provider-variation reports
    • Geographic and temporal review for implausible travel, overlapping services, or excessive daily volume
    • Denial, appeal, refund, complaint, and audit-finding trend analysis

    A Practical 90-Day Audit-Readiness Plan

    Days 1–30: Establish Control

    Assign compliance responsibility; adopt or refresh the compliance plan; identify high-risk services; preserve applicable policies and coverage materials by date of service; and inventory prior audits, refunds, denials, and complaints.

    Days 31–60: Test the Records and the Data

    Audit selected records across clinicians and service lines. Reconcile documentation to claims. Review debridement, CAMPs, modifiers, E/M with procedures, wound measurements, product units and wastage, credentialing, and place of service. Compare utilization among providers.

    Days 61–90: Correct and Verify

    Educate staff using the actual findings, correct workflows, evaluate potential overpayments with appropriate professional guidance, document corrective action, and perform a focused re-audit to confirm sustained improvement.

    Before the Audit Letter Arrives

    • Create a centralized process for mail, portal notices, ADRs, subpoenas, and contractor requests.
    • Designate who will lead clinical review, coding review, legal review, communication, and production.
    • Confirm that the submitted record is complete, legible, authenticated, date-specific, and organized.
    • Do not alter a medical record after receiving a request. Follow compliant late-entry, addendum, and correction policies.
    • Build a claim-to-document crosswalk so reviewers can locate the support for each billed service and unit.
    • Perform an independent pre-submission review and preserve exactly what was submitted.
    • Track deadlines, determinations, repayment activity, and appeal rights in a single audit log.

    Conclusion: Proactive Audit Readiness

    The establishment of the National Fraud Enforcement Division does not change the fundamentals of wound care compliance. It reinforces the direction of travel: centralized enforcement, coordinated investigations, and increasing reliance on data to identify unusual billing and utilization patterns.

    The appropriate response is preparation, not panic. If your organization does not have a compliance program, start one. If you are not auditing records, start now. If you cannot explain your debridement patterns, CAMP utilization, modifiers, product units, documentation trends, and provider-level variation, begin reviewing the data before an auditor does.

    Proactive audit readiness means finding concerns early, correcting them responsibly, educating clinicians and staff, and proving that corrective action worked. In the current environment, that is not merely a compliance best practice. It is an essential part of protecting patients, providers, and the long-term viability of wound care services.

    Author

    B. Moira Sykstus, CHC, CPCO, CPMA, RRT, DAPWCA is Chief Compliance Officer for Redemption Revenue & Compliance Services. Her work focuses on healthcare compliance, Medicare audit readiness and defense, revenue-cycle risk, wound care documentation, and provider education.

    Sources and Editorial Note

    • U.S. Department of Justice, Final Rule, “Establishing the National Fraud Enforcement Division,” 91 Fed. Reg. 53357 (Aug. 18, 2026), effective Aug. 24, 2026.
    • The wound care audit priorities and readiness strategies in this article are educational recommendations and risk-assessment topics. Active audit issues, coverage requirements, and documentation standards vary by contractor, jurisdiction, setting, payer, product, and date of service. Verify requirements applicable to the claim under review.

    Disclaimer

    This article is provided by Redemption Revenue & Compliance Services for general educational and informational purposes only. It is not legal advice, does not create an attorney-client or consultant-client relationship, and should not be relied upon as a substitute for advice from qualified legal counsel or other professionals familiar with an organization’s specific facts.

    Laws, regulations, agency guidance, coverage requirements, enforcement priorities, and interpretations may change. Providers and suppliers remain responsible for evaluating and complying with all requirements applicable to their services, claims, contracts, and operations.

    Examples of analytics, audit exposure, and compliance risks are illustrative and are not findings of wrongdoing, exhaustive lists, or descriptions of every method used by government agencies. Receipt or use of this article does not guarantee compliance, payment, audit outcomes, or protection from investigation or enforcement action.

  • 08/13/2026 8:16 AM | Anonymous

    The APWCA encourages wound care and hyperbaric physicians, advanced practice providers, nurses, practices, hospital-based programs, medical directors, health systems, and other stakeholders to submit comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed Calendar Year 2027 Medicare Physician Fee Schedule.

    Physician Fee Schedule CY 2027 Wound Care Implications v.2.docx

    Comments are due September 14, 2026.

    APWCA is particularly concerned about the potential impact of the proposed policies on two closely connected issues: patient access to medically necessary wound care and the sustainability of the providers and practices that care for Medicare beneficiaries.

    Medicare payment policy does more than determine reimbursement. It can influence where care is available, which services can be sustainably offered, whether practices can maintain an experienced wound care workforce, and whether Medicare beneficiaries can continue receiving timely care in their communities.

    The proposed CY 2027 policies include several provisions with potentially significant implications for wound care, including:

    • reductions in physician professional reimbursement
    • a proposed 50% payment reduction for certain qualifying same-day E/M and procedural services
    • restructuring of G2211
    • continued evolution of CAMP reimbursement
    • changes in practice-expense methodology and facility versus non-facility payment
    • site-of-care payment differences
    • proposed valuation of the new Category I bacterial fluorescence wound imaging code
    • changes affecting Remote Physiologic Monitoring and Remote Therapeutic Monitoring
    • additional policies affecting hospital outpatient wound care

    APWCA supports responsible Medicare stewardship, appropriate utilization, and strong safeguards against waste, fraud, and abuse. At the same time, payment reforms must preserve access to evidence-based care and provide sustainable reimbursement for qualified clinicians and organizations caring for Medicare beneficiaries.

    We therefore encourage providers to tell CMS what these proposals would mean in real-world clinical practice.

    Comments are particularly valuable when they describe:

    • how the proposed policies would affect your ability to continue caring for Medicare beneficiaries
    • whether reimbursement adequately reflects the clinical work, medical decision-making, staffing, supplies, and infrastructure required to provide wound care
    • how proposed payment changes could affect staffing, service availability, or practice sustainability
    • whether policies could shift care from community-based or non-facility settings to higher-cost institutional settings
    • potential effects on rural, homebound, medically complex, and other vulnerable Medicare populations
    • specific recommendations that would preserve patient access while maintaining Medicare program integrity

    You do not need to submit a lengthy policy analysis. Your experience caring for Medicare beneficiaries matters. A concise comment describing the clinical and operational consequences you anticipate can help CMS understand how these policies may function outside of the regulatory and reimbursement models used to develop them.

    Submit Your Comment

    CMS is accepting comments on the proposed CY 2027 Physician Fee Schedule, CMS-1848-P, through September 14, 2026.

    Submit a comment directly to CMS through Regulations.gov

    The official rule states that comments must be received by September 14, 2026, to be assured consideration.

    Your Voice Matters

    APWCA’s mission is centered on improving access to high-quality wound and hyperbaric care through advocacy and collaboration. Protecting patient access also requires ensuring that the clinicians and programs caring for Medicare beneficiaries can remain available and sustainable.

    We encourage every member of the wound care and hyperbaric community to participate.

    Please submit your comments before September 14, 2026, and help ensure that CMS hears directly from the professionals caring for Medicare beneficiaries every day.

  • 06/23/2026 12:21 PM | Anonymous

    American College of Hyperbaric Medicine Applauds Canadian Regulatory Action Regarding Unauthorized Soft-Shelled Hyperbaric Chambers

    The American College of Hyperbaric Medicine (ACHM) applauds Health Canada for its recent public safety communication concerning unauthorized soft-shelled hyperbaric chambers and the potential health risks associated with devices that do not meet established medical, engineering, and safety standards. ( Unlicensed soft-shelled hyperbaric chambers may pose serious health risks - Canada.ca

    The ACHM believes this action highlights an increasingly important issue facing patients, healthcare providers, and regulators worldwide: the distinction between medically supervised hyperbaric oxygen therapy delivered in regulated environments and the growing number of devices marketed directly to consumers without sufficient evidence, oversight, or adherence to recognized hyperbaric safety standards.

    Hyperbaric oxygen therapy is a medical treatment that requires appropriate patient selection, physician oversight, trained chamber operators, emergency preparedness protocols, and equipment manufactured to rigorous engineering specifications. Accredited hyperbaric facilities utilize chambers that are subject to recognized regulatory and safety requirements, including applicable FDA 510(k) clearances, compliance with Pressure Vessels for Human Occupancy (PVHO) standards, and manufacturing requirements established through ASME and related engineering codes designed to ensure structural integrity and patient safety.

    These standards exist for a reason. Hyperbaric chambers are pressure vessels intended for human occupancy and must be designed, tested, maintained, and operated according to strict specifications. Properly regulated systems incorporate extensive safety measures, including fire protection systems, pressure control systems, emergency procedures, maintenance requirements, and operator training that may not be present in unauthorized or unregulated environments.

    The ACHM remains concerned that many soft-shelled devices are marketed in a manner that may lead consumers to believe they are receiving the same treatment as that delivered within accredited medical hyperbaric programs. In reality, there are substantial differences in engineering standards, operational oversight, oxygen delivery systems, emergency capabilities, physician supervision, and clinical evidence supporting use.

    The College echoes concerns raised internationally regarding:

    • Use of chambers lacking appropriate regulatory clearance or authorization.
    • Devices not manufactured to recognized PVHO and applicable engineering standards.
    • Unsubstantiated medical claims and unsupported therapeutic marketing.
    • Potential fire and oxygen-enriched environment hazards.
    • Lack of trained hyperbaric personnel and physician oversight.
    • Delayed diagnosis and treatment of serious medical conditions.
    • Inadequate emergency response capabilities in non-medical settings.
    • Patient confusion regarding evidence-based hyperbaric oxygen therapy versus wellness-oriented products.

    The ACHM strongly supports the principle that patients deserve accurate information regarding the capabilities, limitations, and safety requirements associated with hyperbaric technologies. Hyperbaric oxygen therapy has demonstrated clinical benefit for specific evidence-based indications when delivered appropriately; however, patient safety must always remain paramount.

    The College encourages patients to seek consultation with qualified hyperbaric medicine providers and to receive treatment in facilities that adhere to recognized regulatory, engineering, and clinical standards.

    The ACHM also recognizes the efforts of organizations such as the Wound Healing Alliance (WHA) in raising awareness regarding unauthorized hyperbaric devices and promoting evidence-based hyperbaric medicine practices.

    As hyperbaric medicine continues to advance, the ACHM supports collaboration among regulatory agencies, manufacturers, clinicians, researchers, and patient advocates to ensure that innovation occurs within a framework that prioritizes safety, scientific evidence, transparency, and patient protection.

    Patient safety is not optional. Engineering standards, physician oversight, and evidence-based practice remain the foundation of responsible hyperbaric medicine.

    Tyler Sexton, MD, MAPWCA
    President
    American College of Hyperbaric Medicine (ACHM)

    For additional information:

    About the American College of Hyperbaric Medicine

    The American College of Hyperbaric Medicine is committed to advancing the science, safety, education, and clinical practice of hyperbaric medicine through physician leadership, evidence-based care, professional collaboration, and patient advocacy.

  • 02/03/2026 10:24 AM | Anonymous

    B. Moira Sykstus, MHA, CPCO, CPMA, RRT, CHT, DAPWCA

    Over the past two years, Medicare’s oversight of skin substitute products has shifted from targeted program-integrity review to a level of enforcement that many providers now describe as existential. Across the country, wound care practices—many of which serve the most medically complex and socially vulnerable patients—are reporting debilitating financial losses, forced closures, and in some cases, the loss of Medicare billing privileges, even while disputed claims remain under formal appeal.

    These outcomes raise urgent questions not only about audit methodology, but about Medicare’s obligations to providers and beneficiaries under federal law.


    The human cost of retrospective enforcement

    Skin substitute therapies are not theoretical services. They are applied to patients with chronic, non-healing wounds, often after months or years of unsuccessful conservative care. Providers purchase these products up front, at costs that can exceed thousands of dollars per unit, with no guarantee of reimbursement once an audit is initiated.

    When Medicare later recoups payment—sometimes months or years after care was rendered—the provider does not merely lose revenue. They lose capital already expended, with no mechanism to recover those costs from manufacturers or distributors. Unlike an evaluation and management service, a skin substitute application leaves behind irreversible financial exposure.

    In recent enforcement actions, providers report that:

    • Entire payment streams have been frozen based on a small number of disputed claims;

    • Extrapolation methodologies have multiplied alleged overpayments far beyond the original audit sample;

    • Practices have been forced to lay off staff, reduce services, or close entirely;

    • In at least one reported instance, a provider’s Medicare billing privileges were revoked on the basis of three claims, all of which were under timely appeal.

    For those practices, the appeals process offered no meaningful protection. By the time due process could be exercised, the business no longer existed.

    When “fraud” becomes a label, not a finding

    Medicare regulations clearly distinguish between fraud, abuse, and payment error. Fraud requires intent. Abuse requires reckless disregard. Documentation disputes and medical-necessity disagreements are meant to be resolved through the claims and appeals process.

    Yet in the current enforcement climate, providers report that allegations of fraud are sometimes asserted before appeals are exhausted, and in some cases before adjudication at any appeal level. Payment suspensions, recoupments, and privilege revocations proceed while providers are still exercising rights explicitly granted under the Medicare statute.

    This approach risks transforming fraud from a legal conclusion into a procedural shortcut, applied when spending patterns are unpopular or politically untenable, rather than when evidence supports intentional wrongdoing.


    Due process delayed is due process denied

    Medicare’s appeals system is designed to ensure fairness. Providers are entitled to:

    • Redetermination and reconsideration;

    • Administrative Law Judge (ALJ) review;

    • Judicial review where appropriate.

    However, these protections are meaningful only if providers can survive long enough to use them.

    When payment is suspended or recouped immediately—particularly in high-dollar service lines like skin substitutes—the appeals process becomes academic. A practice that cannot meet payroll or pay vendors cannot wait years for an ALJ decision, even if the ultimate ruling would favor the provider.

    This reality has led many compliance professionals to question whether current enforcement practices effectively nullify statutory appeal rights, undermining the procedural safeguards Congress intended.

    Medicare’s obligations—to providers and to patients

    Medicare’s responsibilities extend beyond safeguarding the Trust Fund. Under federal law, the program has dual obligations:

    To patients:

    • Ensure reasonable access to medically necessary care;

    • Avoid policies that drive providers out of underserved areas;

    • Support continuity of care for beneficiaries with complex medical needs.

    When wound care programs close or curtail services due to audit pressure, patients lose access to advanced therapies that may prevent infection, hospitalization, or amputation.

    To providers:

    • Apply coverage policies prospectively, not retroactively;

    • Enforce compliance in a manner that is proportional and evidence-based;

    • Respect due process rights throughout the audit and appeals continuum;

    • Distinguish clearly between policy disagreement and fraudulent conduct.

    A system that penalizes good-faith providers for operating within existing coverage guidance—only to later revise payment policy—risks eroding trust and participation in the program itself.

    A path forward

    None of this is an argument against oversight. Fraud should be identified and addressed decisively. But indiscriminate enforcement harms the very goals Medicare seeks to achieve.

    A more balanced approach would include:

    • Targeted audits focused on demonstrable outliers;

    • Suspension of recoupment while timely appeals are pending;

    • Clear, prospective guidance when payment policy changes;

    • Recognition of the unique financial exposure inherent in high-cost biological therapies.

    Without such reforms, the current trajectory threatens to replace compliance with fear—and patient care with avoidance.

    Conclusion

    The story of skin substitute audits is no longer just about documentation or utilization. It is about whether Medicare’s enforcement mechanisms respect the rule of law, economic reality, and patient access.

    When compliant practices close, when privileges are revoked mid-appeal, and when providers are financially destroyed before due process is complete, the system has failed—not just providers, but the beneficiaries it exists to serve.


  • 04/07/2025 11:49 AM | Anonymous member

    Attention APWCA Members & Stakeholders:

    CALL TO ACTION
    We need your voice once again!

    A peer-reviewed manuscript accepted to be published in the Journal of Wound Care The hidden costs of limiting access: clinical and economic risks of Medicare’s future effective cellular, acellular and matrix-like products (CAMPs) Local Coverage Determination - has become available and makes it clear: Medicare’s forthcoming LCD “Skin Substitute Grafts/Cellular and Tissue-Based Products for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers,” set to take effect April 13, 2025, will cause significant harm to the patients we serve.

    This policy imposes a rigid cap of eight CAMP applications over a 16-week episode of care regardless of clinical response. As providers on the front lines of wound care, we know this will:

    • Worsen outcomes by increasing amputations, hospitalizations, and ED visits
    • Restrict access for the most vulnerable Medicare beneficiaries
    • Prevent physicians from exercising clinical judgment and practicing according to training
    • Ignore critical real-world evidence that proves the value of these treatments

    While the Alliance of Wound Care Stakeholders recently voiced support for the LCD, the APWCA strongly disagrees with its current form and urges Congress to intervene. Our patients deserve better.

    What You Can Do

    We’re asking every APWCA member to email one or more of the Congressional contacts listed below and urge them to oppose this future effective LCD as written. Tell them it puts patients at risk, undermines medical practice, and widens disparities.

    Personalize your message with:

    • Your experience treating hard-to-heal wounds
    • The impact of CAMPs on patient outcomes
    • Your concerns with a one-size-fits-all reimbursement cap

    Legislators the APWCA Encourages Our Members to Contact - Organized by State

    Alabama

    California

    Colorado

    Florida

    Georgia

    Indiana

    Iowa

    Massachusetts

    Minnesota

    Missouri

    New York

    North Carolina

    Pennsylvania

    Tennessee

    Texas

    Utah


    Download Article

    Let Congress hear from the clinicians who know the risks best. Contact them today—before April 13.

    Thank you for your dedication to evidence-based care and patient advocacy.


    Sincerely,

    The APWCA Leadership Team

    www.apwca.org


  • 09/17/2024 9:14 AM | Anonymous member

    In support of its ongoing efforts to enhance quality wound care through promoting inter-professional collaboration, the American Professional Wound Care Association (APWCA) is launching several Special Interest Groups (SIGs). We are inviting interested individuals to join and participate in these SIGs.

    • Limb Salvage/Preservation
    • Advanced Practice Practitioner (APP)
    • Coding, Compliance and Reimbursement
    • Mobile Wound Care/Post Acute Care
    • Nutrition (RD/RDN)
    • Physical Therapy (PT)
    • Podiatry (DPM)
    • Research
    Please click here to express your interest.
  • 07/04/2024 7:00 AM | Anonymous member

    Ever wish your MAC (Medicare Administrative Contractor) had a report card you could fill out? They do! 

    How Can I Give Feedback About My MAC?

    · J5 - Wisconsin Physician Services

    · J6 - National Government Services

    · J8 - Wisconsin Physician Services

    The links above send you to an email address specifically for provider and beneficiary feedback regarding their specific MACs. Send a shout out for a great interaction, or a wish list for interactions that may not meet your expectations.

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