October 16, 2023

On October 13, APMA supported its Palmetto Jurisdiction Contractor Advisory Committee (CAC) representatives and joined with the American Academy of Dermatology Association (AADA) in submitting comments to Palmetto that raised concerns with proposed Local Coverage Determination (LCD): Surgical Treatment of Nails (DL39258) and proposed Local Coverage Article (LCA): Surgical Treatment of Nails (DA59028). APMA and AADA supported four limitations listed in the proposed LCD, but requested that Palmetto not include the following under its list of limitations for the final LCD:

• Repeat nail excision on the same toenail or fingernail following a complete nail excision for permanent removal
• When a complete nail avulsion is performed, a repeat nail avulsion of the same toenail or fingernail performed more often than every 32 weeks (eight months) for toenails or every 16 weeks (four months) for fingernails

APMA and AADA suggested that Palmetto may allow these repeat procedures only with the submission of the KX Modifier as outlined in the comment letter.  

APMA has been involved in advocacy for the past couple of years in partnership with our CAC representatives to improve existing and proposed CMS and MAC policies related to surgical treatment of nails. Follow the APMA Weekly Focus and other APMA publications to keep up to date on APMA’s advocacy activities.

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