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Policy Updates on Surgical Dressings, Wound Dressing Classifications, and More

22May , 2024

Achieved updates in surgical dressing policy after educating durable medical equipment Medicare Administrative Contractors (DMEMACs) about issues. Following submission of a letter to the Centers for Medicare and Medicaid Services (CMS) contractors flagging concerns, the Alliance met with CMS DMEMAC medical directors in January to elevate the ongoing surgical dressings claims processing issues and inconsistent denials that have created a lack of access to alginate and other fiber gelling dressings. The Alliance also addressed issues regarding surgical dressing modifier quantity limitations and a lack of alignment in the claims processing system with the HCPCS and modifiers when a category of dressing is used for multiple wounds. We shared recommendations for process improvements and, at the DMEMAC medical directors’ request, submitted proposed policy revision language for consideration to address issues.

Led advocacy effort to seek withdrawal of Food and Drug Administration (FDA) proposed rule on classification of wound dressings with antimicrobials. The Alliance submitted comprehensive comments to the FDA's proposed rule and companion amendments on classification of wound dressings and washes that contain antimicrobials (eg, silver, polyhexamethylene biguanide, hypochlorous acid, and iodine) and other chemicals (eg, honey, petrolatum). Following release of the policy, the Alliance quickly formed a member workgroup of regulatory experts to assess impacts and develop recommendations, met with FDA staff to voice concerns, educated members, and mobilized stakeholders to submit aligned comments requesting withdrawal of the policy for further vetting given its many ambiguities and gaps.


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