Submitted Comments

Items Related to Pneumatic Compression

January 7, 2016

Letter to DMEMAC medical directors requesting that the LCDs for pneumatic compression devices conform to the binding national coverage determination

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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