Wednesday, May 8, 2024

DMACs and PDAC

Brett R. Saunders, CPO, FAAOP

It was my understanding that the PDAC was the CMS/Medicare contractor that was tasked with establishing the appropriate HCPCs L Code for any given device as described on their website:

Noridian Administrative Services, LLC (NAS) has served as the Pricing, Data Analysis and Coding (PDAC) Contractor since August 2008. The PDAC performs the following activities:

Receives, evaluates and processes coding verification applications for DMEPOS
Establishes, maintains and updates all coding verification decisions on the Product Classification List that is available on DMECS
Provides coding guidance for manufacturers and suppliers on the proper use of the Healthcare Common Procedure Coding System (HCPCS)
Maintains and publishes the NDC/HCPCS Crosswalk and OACD pricing files
Conducts DMEPOS data analysis
Yet, now I am seeing where the DMACs are both requiring limited Lcode use for particular devices that conflicts with the PDAC decisions, such as with microprocessor knee units, as well as redefining characteristics of devices as they did with AFOs.

The DMACs are even adding that “the use of additional HCPCS codes other than those specified …, either specific codes or NOC [i.e., L5999) codes, for other add-ons, functions or features is considered unbundling and thus is incorrect coding.”

What is a provider to do when the PDAC and MAC have different directives on a particular item/service?

Are the DMACs allowed to ignore the PDAC decisions?

Has anyone gone through a review/audit/appeal that involved this issue?

Thank you,

Brett

Brett R. Saunders, CPO, FAAOP
[email protected]
761 County Road 466
Lady Lake, FL 32159
(352) 259-9749 Phone
(352) 259-8209 Fax

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