Notes - Negative Wound Pressure Disposables

 Over the years, there's been an expansion of Medicare's incident-to benefit.   Historically, allergists could not give patients use-at-home allergens (for desnsitization), and there had to be a standalone Medicare benefit just for home use allergens given out by the allergist.  It's in statute.

Later, around 2010, early in my CMS consulting career, I was part of teams working with Spiracur, which made home-use disposable wound care negative pressure devices.  It wasn't a DME benefit (not "durable equipment" nor "a wound dressing" (in the eyes of CMS), nor was it "incident to" a physician (taken home for use).   Eventually the disposables were incorporated in AMA RVU practice expense, but the point is, it was a debated issue.

Fast forward to 2023, and there are several codes for ambulatory monitoring or feedback that now include "incident to" services like devices used by the patient at home or monthly software charges for it.  I calll this, the little-noticed, or little-noted, evolution of "incident to."

(The concept is alive and well in the "SAD, self administered drugs" body of policy and rules, which can be highly contentious and is rooted in incident-to policy.)

I noticed there was recent legislation aka "leg fix" for negative wound care devices.

https://www.cms.gov/regulations-and-guidance/guidance/transmittals/2023-transmittals/r12382bp

https://www.cms.gov/regulations-and-guidance/guidance/transmittals/2023-transmittals/r12382cp

Small note, note that the transmittal is a "fix" of a prior transmittal, it's a festival of details.