MAC and Wound Management Stakeholder Report Cards for New LCD and LCD Reconsideration Processes

Information regarding coding, coverage, and payment is provided as a service to our readers. Every effort has been made to ensure accuracy.  However, HMP and the author do not represent, guarantee, or warranty that coding, coverage, and payment information is effort-free and/or that payment will be received. 

The November 2018 Business Briefs explained the new Local Coverage Determination (LCD) and LCD Reconsideration processes that the Medicare Administrative Contractors (MACs) were mandated to implement beginning on January 8, 2019. Because the new processes have now been in place for over a calendar quarter, this author is sharing a report card of each MAC’s performance in the new coverage processes (see Table 1a and 1b). In addition, this author has provided a self-checklist for each wound management stakeholder to create a personal report card that reflects full participation in the new LCD processes (see Table 2). 

As you review the MAC report cards, you will find that:

• All the MACs are aware of the new required  LCD and LCD Reconsideration processes and have published guidelines on their websites.
• Most of the MACs have provided guidelines for requesting informal LCD meetings.
• The MACs are beginning to comply with the new regulations for publishing the clinical evidence that was used to make coverage decisions. However, many of the required evidence elements are still not provided.
• Half of the MACs have removed codes from their LCDs as they are mandated to do.
• Most of the MACs have not released new draft wound management-related LCDs since the new regulations went into place in January.  Therefore, we cannot rate their communication performance about draft and final LCDs and about open LCD meetings. However, their website guidelines clearly indicate that they intend to follow the communication requirements. 
• The durable medical equipment MACs followed all the new guidelines for making the Contractor Advisory Committee (CAC) meetings open and transparent to the public. The A/B MACs followed all the guidelines, except for releasing the names of the CAC members. 
• All the MACs have appropriately archived their retired LCDs.

As you can see, most of the MACs are doing their part to comply with the new LCD and LCD Reconsideration processes. Now each wound management stakeholder should participate in these new coverage processes. We have complained about these coverage processes for years. Now that the processes have become more transparent and inclusionary, wound management physicians and other qualified health care professionals, providers, revenue cycle personnel, manufacturers, distributors, et cetera, should take advantage of participating in all available coverage opportunities. If you did not answer yes to all the questions that pertain to you on the stakeholder report card, you should make a concerted effort to participate in the new processes. 

You asked for it! You received it! Now you should make the most of it! 

Kathleen D. Schaum is a founding member of the Today’s Wound Clinic editorial advisory board and oversees a consulting business. She can be reached for consultation and questions by emailing kathleendschaum@bellsouth.net.