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Alliance of Wound Care Stakeholders

The Alliance of Wound Care Stakeholders has been busy in 2016, continuing its advocacy and educational outreach in the regulatory, legislative, and public arenas. An association of physician and clinical organizations focused on promoting quality care and access to products and services for patients with wounds and the providers who treat them, the Alliance convenes wound care clinicians to advocate on public policy issues, such as coding, coverage reimbursement, and quality measures that may create barriers to patient access to treatments or care. To ensure that the Alliance's clinical expert perspective is heard, the group has submitted numerous comments to key stakeholders to protect patient and provider access to wound care procedures and technologies. They include the following:


* Quality Measures Development: The Alliance submitted March comments in response to the Centers for Medicare & Medicaid Services (CMS) Quality Measure Development Plan: Supporting the Transition to the Merit-based Incentive Payment System and Alternative Payment Models. The Alliance used the comments to educate CMS on the seriousness of wound care and its multidisciplinary practice. It advocated that wound care quality measures be represented in this plan and that physicians who treat patients with wounds be part of the Technical Expert Panel as CMS continues to develop this plan. Comments can be found at


* Medicare Administrative Contractor Contracting: The Alliance submitted in February comments to CMS regarding its request for feedback on Medicare Administrative Contractor (MAC) contract awarding. Comments focused on the importance of clear accountability and transparency, expressing concerns about contractors exceeding statutory authority, and encouraging the establishment of a range of metrics for MACs as well as pricing, data analysis, and coding contractor. Comments can be found at


* Pneumatic Compression Devices: The Alliance continued to make its case to CMS and Durable Medical Equipment Medicare Administrative Contractors (DMEMACs) that the 2015 local coverage determinations on pneumatic compression devices are improperly and substantively more restrictive than the corresponding national coverage determinations, which is a violation of the Medicare Program Integrity Manual. Read the January letter to DMEMAC medical directors from the Alliance at


* Episode Groups under the Medicare Access and CHIP Reauthorization Act of 2015: The Alliance submitted comments in response to the CMS request for comments on the methodology the agency is using to create Episode Groups under the Medicare Access and CHIP Reauthorization Act of 2015. Comments can be found at



In other news, the Alliance recently welcomed its newest clinical association member, the American Diabetes Association Foot Care Interest Group. They will be represented on the Alliance by Jill Kadish, the American Diabetes Association's associate director of professional engagement, and podiatrist Katherine M. Raspovic, DPM, assistant professor, Department of Plastic Surgery, MedStar Georgetown University Hospital, Washington, DC.


At the recent national meeting of the American Professional Wound Care Association, the Alliance's executive director, Marcia Nusgart, RPh, presented a session on "Regulatory and Legislative Issues Impacting Wound Care Including Physician Payment Reform."


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