CMS releases clarifications regarding NCDs and LCDs

I feel a bit like January, 2000 – much ado about little. Looks like (so far) ICD-10 is a go. I’m not saying there haven’t been bumps in the road, or that there are no obstacles we have yet to recognize, but I think I can say, “so-far-so good.” Something I have spent the last few years deeply involved with is the translation of the National Coverage Determinations (NCDs) to ICD-10. On November 20, 2015, CMS released information regarding feedback on some of the NCD translations and issues discovered in some of the LCD policy translations prepared by the MACs.

Med Learn Matters Article MM9252 Revised explained that the NCDs that received feedback were being re-released in revised CR9252. CMS goes on to explain: “You should be aware that nationally covered and non covered diagnosis code lists are finite and cannot be revised without a subsequent CR. Discretionary code lists are to be regarded as CMS’ compilation of discretionary codes based on current analysis/interpretation. MACs may or may not expand discretionary lists based on their individual local authority within their respective jurisdictions.”

The revised CR9252 included 26 NCD policies that had been revised since their original publication.

News from Pennsylvania

I saw an article by the Pennsylvania Medical Society titled, “26 National Coverage Determinations Policies Have Not Transitioned to ICD-10 – What This Means for Providers.” Actually, all the policies had been translated to ICD-10, but there are edits in the policies that make it very challenging to accurately adjudicate claims. CMS and MACs are working on the edits with the goal of implementing the 26 policies fully in ICD-10 on January 4, 2016.

The list of impacted policies includes:

  1. Colorectal Cancer Screening Tests
  2. Dermal Injections for the Treatment of Facial Lipodystrophy Syndrome (LDS)
  3. Intravenous Immune Globulin for the Treatment of Autoimmune Mucocutaneous Blistering Diseases
  4. Artificial Hearts and Related Devices
  5. Cardiac Output Monitoring by Thoracic Electrical Bioimpedance (TEB)
  6. Intravenous Iron Therapy
  7. Photodynamic Therapy, Ocular Photodynamic Therapy (OPT), Photosensitive Drugs and Verteporfin
  8. Bariatric Surgery for Treatment of Co Morbid Conditions Related to Morbid Obesity
  9. Vitrectomy
  10. Deep Brain Stimulation (DBS) for Essential Tremor and Parkinson’s Disease
  11. Hyperbaric Oxygen Therapy
  12. Home Prothrombin Time/International Normalized Ratio (PT/INR) Monitoring for Anticoagulation Management
  13. Vagus Nerve Stimulation
  14. Bone (Mineral) Density Studies
  15. Screening Pap Smears and Pelvic examinations for Early Detection of Cervical or Vaginal Cancer
  16. Medical Nutrition Therapy
  17. Extrcorporeal Photopheresis
  18. Ventricular Assist Devices
  19. Percutaneous Transluminal Angioplasty (PTA)
  20. Extracorporeal Immunoadsorption Using Protein A Columns
  21. External Counterpulsation (ECP) Therapy for Severe Angina
  22. Infrared Therapy Devices
  23. FDG PET for Infection and Inflammation
  24. Adult Liver Transplantation
  25. Percutaneous Image Guided Breast Biopsy
  26. Erythropoiesis Stimulating Agents (ESAs) in Cancer and Related Neoplastic Conditions

My take

First, I want to offer kudos to CMS. I think they have done an amazing job in leading the industry through the conversion. When you think of the sheer number of codes involved, not only ICD but CPT and HCPCS, and the number of policies impacted, plus all the other documentation in the myriad CMS publications, the fact that only 26 policies require extra scrutiny is pretty amazing.

Yes, there are providers receiving denials on codes listed in the 26 policies above. I suggest checking the NCD – if the ICD-10 code you are using is accurate, and appears in the policy, resubmit the claim after January 4, 2016.

Also check your MACs website; some are publishing lists of codes that will pass their system’s edits for the impacted NCDs now. As the article by the Pennsylvania Medical Society suggests, some MACs are also experiencing issues with some codes in LCDs being erroneously denied. If this is happening to your facility or practice, ask for guidance from your MAC on resubmission requirements.

The article also suggests “Providers are being asked to report any claim denials that result due to ‘missing or dropped ICD-10’ codes by emailing that information to the CMS ICD-10 Ombudsman.”

Barbara Aubry is a regulatory analyst for 3M Health Information Systems.

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