Updated November 21, 2022
On November 18, APMA joined with its CGS Carrier Advisory Committee (CAC) Representatives in submitting a comment letter to CGS Medicare Administrative Contractor (MAC) regarding a draft Local Coverage Determination (LCD) and Local Coverage Article (LCA) related to Cellular and Tissue Based products (CTPs) for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers. In developing this letter, APMA sought feedback from our CGS CAC representatives in Ohio and Kentucky and collaborated with APMA’s Clinical Practice Advisory Committee (CPAC) in drafting the comments.
APMA has a broad network of CAC representatives throughout the country who monitor changes in Medicare coverage, billing, and coding policies and share information between APMA’s members and APMA Headquarters. APMA previously worked with the American Society of Plastic Surgeons (ASPS) and the American Society for Surgery of the Hand (ASSH) similar comments to Novitas and First Coast Services Options (FCSO).
In the letter, APMA underscored the medical, social, psychological, and financial burdens that chronic wounds present for patients and health-care systems, and took particular exception to limitations on the number of applications of CTPs, required use of RT or LT Modifier, and the incomplete set of included ICD-10 codes. The letter is available in its entirety here.
APMA will keep members informed about these matters as more details become available. For additional information, contact APMA at email@example.com or contact your Carrier Advisory Committee representative for further assistance related to MAC issues.