Have You Committed to Participate in the New Local Coverage Determination Process?

Wound management stakeholders of all disciplines have often raised concerns about the inconsistent process for local coverage determinations (LCDs) and the process for LCD reconsideration requests. However, most have failed to “make their voices heard” about Medicare’s fee-for-service draft and final LCDs. Reasons for the lack of participation in sharing opinions and insight among these professionals tend to stem from a perceived lack of caring about coverage opinions on the part of the Medicare Administrative Contractors (MACs). Wound care stakeholders are not alone in their concerns about these coverage processes. In response to many requests among healthcare providers, the 21st Century Cures Act of 2016 mandated the Centers for Medicare & Medicaid Services (CMS) to improve transparency of the LCD process and to open the process to all interested parties. This article will review wound care stakeholders’ typical frustrations about the two LCD coverage processes and discuss the new LCD process and LCD reconsideration request process released by CMS. (See the Table at right.)

SUMMARY
All wound management professionals and providers should be excited about the new LCD process. And, every wound management stakeholder should take personal responsibility for participating in the Medicare fee-for-service coverage process. To receive announcements about proposed and final LCDs, sign up for your MAC’s coverage listserv. During comment periods, personally comment, encourage your professional societies and advocacy groups to comment, and encourage impacted beneficiaries to comment. You may even want to investigate how you can become a member of your state’s CAC. Remember that anyone who has access to published clinical evidence can now request a new LCD. If active LCDs do not seem to reflect current published evidence, anyone can request an LCD reconsideration. Don’t pass up this opportunity to participate in the new LCD coverage processes. Refer to the official change request (CR10901) that includes the complete revision of Chapter 13 of the Medicare Program Integrity Manual online: www.cms.gov/regulations-and-guidance/guidance/transmittals/2018downloads/r829pi.pdf n

Kathleen D. Schaum oversees her own consulting business and is a founding member of the TWC editorial advisory board. She can be reached for consultation and questions at kathleendschaum@bellsouth.net