Submitted Comments

February 19, 2016
The Alliance submitted comments to CMS on the Medicare Administrative Contractors (MAC) contracting process. Comments noted that CMS failed to describe what “exceptional MAC performance” means and how that will be measured. The Alliance recommended that CMS be required to provide the metrics on how the contractors are being measured, as transparency would help clinicians and other stakeholders who interact with the Medicare Administrative Contractors (MACs). 
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January 7, 2016
The Alliance submitted a letter to DMEMAC Medical Directors on the LCDs for pneumatic compression devices (PCD). The letter reiterated past comments submitted addressing the LCD for Pneumatic Compression Devices (PCDs) that took effect on December 1, 2015. The Alliance again emphasized its opinion that the scope of coverage under the LCDs is far more restrictive than the NCD for pneumatic compression devices. We again assert that the new LCD does not merely “clarify” existing requirements as stated by the DMDs, but rather adds a number of new substantive binding criteria that are more restrictive than the NCD; the practical effect of these changes eliminates beneficiary access to PCDs that has long been afforded by the NCD. There is no doubt that if a beneficiary had access to a PCD on November 30, 2015 based on existing criteria, but that same patient no longer qualified for PCD coverage on December 1, 2015 based on new LCD criteria, then those new criteria are more restrictive – and that is the case for a large number of beneficiaries.
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