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Proposed WPS LCD Sets An Alarming Precedent For Ulcer Debridement

Jeffrey D. Lehrman DPM FASPS CPC

10/09/2019

Do you really care about preventing amputations? If so, now is your time to show it. WPS Government Health Administrators, the Part B Medicare Administrative Contractor for Michigan, Indiana, Iowa, Nebraska, Kansas, and Missouri, has issued a draft local coverage determination (LCD) DL37228, which states:

1. Debridement for diabetic foot ulcers is not necessary and not covered

2. Debridement for stage II pressure ulcers is not necessary and not covered

3. Debridement of ANY ulcer not deeper than the layer of skin is not necessary and not covered.

What We Can Do To Stop This Proposed LCD

The good news is that this LCD is only “proposed” and we all have an opportunity to comment on it. One can accomplish this by simply writing an email to policycomments@wpsic.com and indicating that you are commenting on LCD DL37228. Then tell them what you think about this! They may be interested to hear about the morbidity and mortality associated with the ulcers we treat and how awful it is when patients are denied this much needed care.

The comment period closes on November 10, 2019 so be sure to act soon! The communication does not have to be long and involved. Even a quick email to share your thoughts can have an impact.

Who Is Affected By This Proposed LCD?

All of us! While WPS only governs the six states listed above, this proposed LCD would establish a very dangerous precedent and often one payer/administrator follows the lead of another. On the other hand, a robust response persuading WPS to change this proposal could dissuade others from trying to limit care to patients in the same manner.

Furthermore, this impacts more than just providers. This can absolutely impact our industry friends, hospital administration, wound care center administrators and really anyone involved with wound care in any way. Do not delay! Please spread the word and write that email!

Dr. Lehrman operates Lehrman Consulting, LLC, is a consultant to the APMA Health Policy and Practice Department, serves as an expert panelist on Codingline, and is a Certified Professional Coder. Follow him on Twitter @DrLehrman.

References

1. Centers for Medicare and Medicaid Services. Proposed Local Coverage Determination (LCD): Wound Care (DL37228). Available at:

https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=38447&ver=3&SearchType=Advanced&CoverageSelection=Local&PolicyType=Draft&s=-&AdvSearchName=8&KeyWord=wound+care&KeyWordLookUp=Doc&KeyWordSearchType=Exact&kq=true&bc=IAAAACAAAAAA& . Accessed September 30, 2019.