September 8, 2023
The Alliance engaged CMS Coverage & Analysis Group senior staff to alert them the concerning patient care issues surrounding the Novitas/First Coast Service Options/CGS Admistrators local coverage determinations and local coverage articles on CTPs ("skin substitutes") for the treatment of diabetic food ulcer and venous leg ulcer. Requested CMS intervention to delay implementation or withdraw the LCDs/LCAs completely. "These LCDs provide the latest example of contractor policies that have raised substantive and procedural concerns within the clinical community. While the Alliance believes there is a need for a more thorough discussion with CMS and the MACs regarding these and other issues, we write today only with the goal of avoiding significant and impending harm to patients that would result from implementation of these LCDs and LCAs. We implore CMS to intervene," the Alliance wrote.

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