Tuesday, January 15, 2019

Very Brief Blog: CMS Slightly Updates Its New 2019 Rules for LCDs

On October 3, 2018, CMS released a major update of its rules for new LCDs and for LCD reconsiderations.  This was a major change (including large deletions) in the longstanding processes found in Program Integrity Manual, Chapter 13, LCDs.  My original article here.

On January 11, 2019, CMS released a minor revision or tweak to this large update.  The new January updates seem minor, but are hard to discern, because all the new pages of text are in "red" (including this week's tweaks).   The new document is Changer Request 10901, Transmittal 854, Released January 11, 2019, with effective date of September 26, 2018 and implementation date of January 8, 2019. 

Find the change document here.

Find the changes in context in PIM Chapter 13 as a whole, here.

The NGS MAC, for example, has updated its websites with rules for the new "LCD Request" process, A56198, here.  A different page of rules is for the "Reconsideration" of an existing LCD, A52842, here.

Some think that with the new instructions, LCDs won't contain any coding references as all (no CPT codes.)  This seems confusing, since most people start with a CPT code, and search on that to see whether there are any LCDs on it.  I'm not sure if I've gotten that correct or not.

Nerd Note!

I found at least one typo.  In the online full chapter (here),  refers the reader to the listing of specialties in a Contractor Advisory Committee/CAC in Exhibit 3. And in the Transmittal, 10901, Business requirement 7.1 states that MACs shall endeavor to have full CAC specialist panels in every state.   But if you go to the separate PDF for all exhibits, Exhibit 3 (which should be a specialties list, like surgeon, psychiatrist, internist, etc) is simply missing.