Wednesday, March 23, 2016

MAC LCD Comments Review: How Long?

Medicare MACs are required to post draft LCDs for 45 days of public comment and then to allow a 45 day public notice when the LCD is finalized and pending its effective date.

How long does the review of comments take?  It's highly variable/..but around seven months.

I pulled data today from the Noridian J-E Part B website for draft LCDs under comment and review periods (here).  Eight LCDs were recently finalized, with an average contemplation time of 200 days (almost 6-7 months), range 101 to 348 days, standard deviation +/- 68 days.

Seven LCDs are in the review process, five of them for 107 days and counting (having been under review since December 7, 2015) and two at 226 days, which is longer than average.

Seven LCDs were recently released and under active public comment until April 10.   Counting review LCDs and newly proposed ones, 15 LCDs are under comment or under review.

The longest review period, at 348 days, was an LCD for varicose veins of the extremities.  The shortest review, at 101 days, was for the Prosigna FDA-approved breast cancer gene panel test.

Screen shot below.  Click to enlarge.  Or: Excel in the cloud here.