October 26, 2022
The Alliance elevated its concerns with CGS's proposed LCD/LCA on Skin Substitutes for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers by providing oral testimony at the Medicare Administrative Contractors' public meeting. The Alliance emphasized its concern that a thorough evaluation and independent review of the evidence had not been undertaken by CGS, as this LCD mirrors the recently-issued Novitas and FCSO LCDs. The Alliance focused its comments on four main areas of concern.
  1. Many of the statements and limitations in the policy do not seem to have the scientific evidence to support them.
  2. Utilization parameters in the draft LCD seem arbitrary, will negatively impact patient care and are not supported in the evidence provided.
  3. There is conflicting/confusing information contained in the draft LCD that in some cases is clinically incorrect.
  4. There are significant procedural issues with the process in which the draft LCD was developed and released.
See the Alliance's full testimony and accompanying slides below. 

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