Practice Management Alert

Question: Are my region’s local coverage determinations (LCDs) affected by the October 2018 adjustments to the Medicare Program Integrity Manual?

Washington, D.C. Subscriber

Answer: In a word, probably. Here are five takeaways from a CMS fact sheet on the Medicare Program Integrity Manual about Chapter 13, which covers LCDs.

1. Provide evidence. More of the onus will be on Medicare Administrative Contractors (MACs) to defend their LCDs with evidence. The MACs will also show how they came to policy conclusions with a “step-by-step” process. They will also need to align their reconsideration policies with those of national coverage determinations (NCDs).

2. Include beneficiaries. Beneficiary involvement is the pervasive theme of the LCD changes. Some of the options will be “informal meetings with MACs,” beneficiary reps on the Contractor Advisory Committees (CACs), publicized CAC meetings, and more discourse.

3. You can make requests. “A novel process by which interested parties in a MAC jurisdiction can request a new LCD,” noted the agency fact sheet.

4. Codes will be removed. In the future, CPT® codes and ICD-10-CM codes will not be part of LCDs. The summary does not go into the details on where these codes will be “relocated” to; it only mentions that they will be “removed” from LCD in the future.

5. Expiration dates come into play. If proposed policies aren’t solidified within one year’s time, CMS advises the MACs retire them.

Resource: Find a more in-depth look at the LCD changes’ fact sheet at www.cms.gov/newsroom/fact-sheets/summary-significant-changes-medicare-program-integrity-manual-chapter-13-local-coverage.