Comments

Items Related to DMEMACs

February 24, 2020

Letter to CMS on Pressure Injury Quality Measures in the IPPS

In a letter to CMS, the Coalition requested that a Hospital Harm - Pressure Injury electronic clinical quality measure (eCQM) be included in the CY 2021 Inpatient Prospective Payment System rulemaking. Pressure injury rate transparency will lead hospitals to identify and implement best practice improvements which will reduce hospital-acquired pressure injuries, the Coalition noted.

SEE COALITION LETTER

November 10, 2019

Comments to WPS Draft LCD for Wound Care

The Coalition submitted comments to WPS addressing the negative pressure wound therapy (NPWT) provisions of its Draft LCD for Wound Care. The Coalition flagged to WPS that NPWT utilization parameters in its policy conflict with existing DMEMAC policy. The Coalition questioned WPS’ rationale for including NPWT in its policy and recommended that WPS eliminate the information on NPWT in its draft and refer providers to the DMEMAC NPWT Local Coverage Determination.
See Coalition Comments

July 9, 2018

Comments to Interim Final Rule on Durable Medical Equipment Fee Schedule Adjustments

The Coalition submitted comments to CMS on the agency's DME Interim Final Rule- which addresses competitive bidding issues. Within the interim final rule, published in May, CMS temporarily increases the fee schedule rates from June 1, 2018, through December 31, 2018, for certain durable medical equipment (DME) items and services and enteral nutrition furnished in rural and non-contiguous areas (Alaska, Hawaii, and U.S. territories) of the country not subject to the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program.

Read Coalition Comment

July 14, 2017

Request letter and appendix to DMEMACs to delay future surgical dressing LCD (L33831)

The Coalition submitted a letter to the DMEMAC medical directors requesting a delay of future surgical dressing LCD (L33831). The Coalition cited the LCD’s flaws in coverage criteria, in violation of current Medicare requirements and congressional intent outlined in the 21^st Century Cures Act as significant flaws in the policy. Furthermore, the Coalition states in its comments that proposals in the LCD would eliminate coverage for hydrogel dressings used for stage II ulcers. The LCD includes other coverage restrictions that lack sufficient evidence to support them or that conflict with established standards of care as well. Finally, the Coalition noted that the LCD does not provide any explanation for prohibiting the use of composite dressings to treat lightly exudative wounds, which also rubs contrary to the standard of care.
Letter Appendix

September 21, 2015

Comments

Items Related to DMEMACs

Letter to CMS on Pressure Injury Quality Measures in the IPPS

Comments to WPS Draft LCD for Wound Care

Comments to Interim Final Rule on Durable Medical Equipment Fee Schedule Adjustments

Request letter and appendix to DMEMACs to delay future surgical dressing LCD (L33831)

Comments to DMEMACs on draft surgical dressings LCD (DL33831) and Policy Article (A54563)

Testimony at the DMEMAC Surgical Dressing LCD Public Meeting

Coalition response to DMEMAC and PDAC letter on non-covered surgical dressing article

Letter to DMEMAC and PDAC on non-covered surgical dressing article

Letter to DMEMACs and PDAC on non-covered surgical dressing article

Comments on the DMEMAC’s Request for Information on Medical Grade Honey as a Surgical Dressing Component

Comments to AHRQ on venous stasis ulcer comparative effectiveness review

Coalition comments to DMEMAC medical directors on two draft LCDs: pneumatic compression and suction pumps

Coalition comments at the DMEMAC meeting on Suction Pump draft LCD

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