Comments to CMS COVID-19 Public Health Emergency Second Interim Final Rule

The Coalition submitted comments to CMS's COVID-19 Public Health Emergency Second Interim Final Rule that provided additional policy and regulatory revisions to provide flexibility during the pandemic. The Coalition focused on issues facing the wound care supplier and manufacturing communities, with specific recommendations for CMS to consider. These included:

• Delaying the DME competitive bidding program;
• Streamline Medicare billing for disposable negative pressure wound therapy (NPWT) furnished at home onto the standard form used by home health agencies;
• Prioritizing DMEPOS suppliers’ access to personal protective equipment for treating COVID-19 patients in their homes;
• Waiving all pre-authorization requirements for DMEPOS patients during the emergency period;
• Extending appeals deadlines, postponing Medicare audits, and defering overpayment recoupment so that DMEPOS providers and suppliers can focus on caring for patients and provide meaningful products and services to impacted patients;
• Adding select codes for negative pressure wound therapy (NPWT) using disposable, non-durable medical equipment to the eligible telehealth list.

See Coalition Comment