May 27, 2022
The Alliance submitted detailed comments and recommendations to Novitas on its Draft LCD on Skin Substitutes for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers (DL35041) and accompanying draft Local Coverage Article (DA54117). In April oral comments submitted at Novitas' public meeting, the Alliance had flagged - among other issues -  provisions in the policy not supported by scientific evidence, as well as conflicting and/or clinically incorrect policy language. In written comments, the Alliance submitted a chart (attachment A)  detailing the specific provisions/policy language it flagged as problematic, the issues of concern underlying to those provisions, specific language changes to address the concern, and the clinical evidence supporting these recommendations. The chart was accompanied by additional attachments, including HCPCS and ICD-10 Codes to be added and a red-lined mark-up of suggested line edits (attachments B-E). See comments and attachments below.

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