APMA Addresses CAC Engagement and Cross Agency Issues with CMS | News | APMA
APMA Addresses CAC Engagement and Cross Agency Issues with CMS

March 13, 2023

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Updated March 13, 2023

Last week, APMA submitted to the Medicare Administrative Contractor (MAC) Workgroup its Principles of Sound Local Coverage Policies and consensus answers to questions raised by CMS and the workgroup. APMA has been working with its Contractor Advisory Committee (CAC) Engagement Coalition to reach these consensus positions.

Previously, on February 7, APMA met with the members of the CAC  Engagement Coalition to review these materials and discuss consensus answers to questions raised by CMS and the MAC Workgroup, which is investigating changes to the CAC feedback process brought about by 21st Century Cures Act. APMA plans to revise the group’s materials and share this information with the MAC Workgroup and with CMS to help improve the process for developing LCDs and LCAs and contribute to more reasonable policies and better beneficiary care

On January 9, APMA had previously gathered the CAC Engagement Coalition to gain consensus and set strategy for its upcoming meeting with the MAC Workgroup. As part of this meeting, APMA shared questions that had been posed by the MAC workgroup as well as a draft document that APMA has created based on feedback by the coalition and stakeholders on Principles of Sound Local Coverage Policies. APMA’s involvement with the MAC Workgroup came about through APMA’s leadership in the CAC process and LCD development as well as the strong working relationships between APMA’s CAC representatives and their contractor medical directors (CMDs).

Previously, on September 30, 2022, APMA and its CAC engagement coalition held a call with CMS in furtherance of their CAC engagement efforts to address cross-agency issues with CMS.

APMA and the coalition have experienced several challenges with the Local Coverage (LC) process in recent years and have brought those concerns to CMS’ Coverage and Analysis Group (CAG). The CAG has considered APMA’s concerns and is working to address many of them on an ongoing basis.

As previously reported in APMA Weekly Focus, the CAG has raised many of our concerns regarding CACs with the MAC medical directors, who have developed a working group to address concerns raised by this group, and with whom we are engaged to continue to work through several issues. However, other issues have hit roadblocks, so APMA requested this meeting with CMS to facilitate cross-agency engagement on these issues to help advance goals of transparency, burden reduction, and sound policy.

Specifically, APMA and the coalition again raised the following issues:

  • Lack of notice and comment regarding articles that determine coverage
  • Proper nomenclature and placement issues for “Articles” across CMS that do not address coverage
  • Performance metrics and additional accountability for MACs , including adhering to LCD timelines, new standards for CAC engagement, requirement to always include a draft LCA with the draft LCD for notice and comment
  • Need for an ombudsman to coordinate these issues

This meeting continues the efforts of APMA and the coalition to address lingering concerns regarding the Local Coverage Determination (LCDs) and Article (LCAs) review process, role of the CAC representatives, and other issues that APMA and our coalition have raised related to changes brought about by the 21st Century Cures Act.

Read more about APMA’s advocacy and the CAC process at www.apma.org/cacpiac and www.apma.org/medicare.

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