Friday, May 20, 2022

CMS Proposed Revisions to Lower Limb Prostheses LCD

Lesleigh Sisson

Draft Policies Release for Comment Bulletin Article

The Centers for Medicare & Medicaid Services (CMS) assigned to the Durable
Medical Equipment Medicare Administrative Contractors (DME MACs) the task
of developing local coverage determinations (LCDs) for processing and
reviewing Medicare claims for Durable Medical Equipment, Prostheses,
Orthoses, and Supplies (DMEPOS). The DME MACs are proposing two revised
LCDs and one new LCD. These LCDs require a 45-day public comment period. *The
comment period for these LCDs begins on Thursday, July 16, 2015 and ends at
Close of (COB) on Monday, August 31, 2015.*

The summaries below highlight only the major points in each LCD. Each draft
LCD should be completely reviewed prior to the preparation of comments.

*External Infusion Pumps* (revision to existing LCD)

– Revises the criteria for reimbursement of intravenous inotropic

*Bowel Management Devices* (new LCD)

– Provides information necessary for processing claims for these
technologies based upon their benefit category coverage status.

*Lower Limb Prostheses* (revision to existing LCD)

– Revises coverage for the provision of definitive prosthetic components
in lieu of an immediate or preparatory prosthesis
– Implements a requirement for an independent medical exam to determine
functional status
– Implements a requirement for a new amputee to participate in a
rehabilitation program prior to the provision of a definitive prosthesis.
– Revises functional level modifiers (K-level modifiers)
– Revises codes for prosthetic feet

We are soliciting comments on these draft policies from physicians,
manufacturers, suppliers and other professionals involved in the ordering
of provision of these items. *For the External Infusion Pump policy, we are
only soliciting comments regarding the revised criteria for the
reimbursement of intravenous inotropic medications.*

We recommend that you distribute these draft policies to selected members
of your organization for review and comment. If you disagree with any
aspect of a policy, you should be very specific in your comment and, if
possible, offer an alternative. You should provide a clinical rationale for
your position including references from the published clinical literature
(e.g. standard textbooks, peer-reviewed journals, etc.). We encourage a
written response if you agree with this policy.

*If you are providing comments on more than one LCD, please provide a
separate communication for each policy with the policy indicated in the
subject line of the submission.*

*All comments will be collected at a single point of contact. Please submit
your comments electronically to the DME MAC medical director at the e-mail
address below no later than Close of Business (COB) on the date indicated
above for close of the comment period for the applicable LCD. *

Stacey V. Brennan, M.D., FAAFP
Medical Director, DME MAC, Jurisdiction B

National Government Services
8115 Knue Rd.
Indianapolis, IN 46250-1936

[email protected]

The comment process requires a public meeting. A joint DME MAC public
meeting will be held on *August 26, 2015, from 08:00 AM EDT until 12:00 PM
EDT *at:

Airport Square Business Park,
1304 Concourse Drive,
Linthicum, MD 21090

Interested parties from any DME MAC jurisdiction may attend this public
meeting. *This meeting provides the opportunity for brief oral
presentations only.* There is no Question and Answer or discussion period
as a part of the meeting. In order for oral presentation comments to be
considered, they must be presented through the formal comment process.

Advance registration is required for attendance at the public meeting and
the registrant must indicate whether participating as a presenter or
attendee (listen only). Registration is online at:
[image: This link will take you to an external website.]

This registration must be completed no later than *COB* *Friday, August 21,
2015. *Registrants must include their name, contact information,
organization, whether attending in person or via teleconference and the
policy(s) upon which oral presentations will be made in their registration

The amount of time allotted to presentations is based upon the number of
registered speakers. There shall be one presentation per company or
organization. The DME MAC medical directors reserve the right to limit
speakers and time as appropriate. Speakers should be prepared to adjust the
length of their presentation depending upon the number of speakers.

**IMPORTANT REMINDER** Suppliers/providers are cautioned not to make any
changes to business practices based upon the information contained in these
draft documents. Drafts are often substantially revised based upon the
comments received. When all comments have been reviewed, revisions will be
considered. The final policies will be published in the CMS Medicare
Coverage Database and on individual DME MAC websites, allowing for adequate
notice before the policies’ effective date.

Refer to each DME MAC web site for additional information about policy
development and copies of the draft LCDs.

Jurisdiction A – [image: This link will take
you to an external website.]

Jurisdiction B – [image: This link will take
you to an external website.]

Jurisdiction C – [image: This link will take you to
an external website.]

Jurisdiction D –

Thank you for your participation in our policy revision process.


Stacey V. Brennan, M.D., FAAFP

On behalf of:

Wilfred Mamuya, MD, PhD

Medical Director, DME MAC, Jurisdiction A

NHIC, Corp.
75 Sgt. William B. Terry Drive
Hingham, MA 02043-1518

[email protected]

Robert D. Hoover, Jr., MD, MPH, FACP

Medical Director, DME MAC, Jurisdiction C

CGS Administrators, LLC
2 Vantage Way
Nashville, TN 37228-1504

[email protected]

Stacey V. Brennan, M.D., FAAFP

Medical Director, DME MAC, Jurisdiction B

National Government Services
8115 Knue Rd.
Indianapolis, IN 46250-1936

[email protected]

Eileen M. Moynihan, MD, FACP, FACR

Medical Director, DME MAC, Jurisdiction D

Noridian Healthcare Solutions
900 42nd Street South
Fargo, ND 58103-2146

[email protected]

Last Updated Jul 16, 2015


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