First Quarter 2008 - Issues in Hematology - ION Solutions

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eimbursement watchon a coverage topic for both Part A or for Part B,even if there were legacy LCDs for consolidation.WPS has also created separate LCDs for PartA services.> In several instances, TrailBlazer selected its ownexisting LCD as the new MAC jurisdiction-widepolicy. TrailBlazer has created one policy that isapplicable for both Part A and Part B services.As CMS awards additional MAC contracts, newapproaches to LCD consolidation could emerge.Understanding your MAC’s rationale behind thedevelopment of a new jurisdiction-wide LCD can helpyour practice determine whether to ask for additionalclarifi cation or to submit comments.EXPRESS YOURSELFComment and notice periods allow providers a chanceto voice their opinions on newly created LCDs. Aminimum comment period of 45 days on any proposedrevision that restricts an existing LCD is required.In addition, a minimum notice period of 30 days isrequired before the policy takes effect. This time periodis very important for providers to be aware of, ascoverage changes could impact the delivery of care aswell as reimbursement for certain treatment regimens ortherapies. MACs are instructed to notify providers aboutpertinent information and to solicit feedback on LCDsthrough bulletins and listservs, meetings, and trainingseminars. MACs in both J4 and J5 have recentlyprovided a 45-day comment period for providers tosubmit comments electronically via email on any of thenew MAC LCDs. These comments have been reviewedby each of the MACs and the MACs have postedseveral revisions to the originally posted LCDs.IT IS IMPERATIVE FORPROVIDERS TO REVIEWNEW LCDS FOR COVERAGECHANGES AND PROVIDEAPPROPRIATE COMMENTSTO THE CONTRACTORWHEN NEEDED.oncologistics volume 7, issue 1 - spring 2008 28As transition activities start taking place in otherjurisdictions, it will be important for providers to:> Monitor the postings of new LCDs for theirrespective region> Review the new LCDs> Provide comment on LCDs if appropriate> Be prepared to submit clinical documentationalong with comments if changes to coverageare requested
oncologistics reimbursement watchAnticipated MAC Award and Transition Schedule*Jurisdictions34, 5, 121, 2, 7, 136, 11, 14, 158, 9, 107/2006 3/20077/2007 6/20089/2007 6/20087/31/2008 6/20099/2008 5/2009* There has been a delay in awarding J2, J7, andJ13 (Cycle 1B anticipated award for September2007). This will likely cause the date of completeimplementation (cutover) for these jurisdictions tobe later than anticipated.1/2007 1/2008 1/2009 1/2010Anticipated MAC AwardsRange of Earliest Completed TransitionsAs new policies are posted, providers may want toconsider examining them and asking the followingquestions as they evaluate the policies:> Are the covered indications for a particular productor treatment regimen inappropriately restrictingcoverage or are particular indications of interest notlisted as covered?> Are the previously available ICD-9-CM codes stillincluded within the LCD (primary and secondaryICD-9-CM codes)?> Do the coverage limitations or utilizationrestrictions hamper services or therapies that werepreviously covered?Emily Phillips, analyst, is a member of theReimbursement Strategy & Solutions consultinggroup within Xcenda’s national consulting practice,where she works on reimbursement projects forclients across the product commercializationspectrum. She assists with research for strategicconsulting projects, new business development,and client strategies and tactical plans.It is imperative for providers to review new LCDs forcoverage changes and provide appropriate commentsto the contractor when needed.It is CMS’ mission to ensure healthcare security forbenefi ciaries by establishing a premier health plan thatallows for comprehensive, quality care and worldclassbenefi ciary and provider service. 4 Through theimplementation of MAC reform, CMS hopes to realizethis mission. Awareness and communication betweenthe provider community and each MAC is critical fora smooth transition. This will also help to incorporateprovider input as part of the policy revision process. ❚References:1. Pub. L. 108-173, 117 Stat 2066, “Medicare Prescription Drug,Improvement, and Modernization Act of 2003,” (MMA 2003)(December 8, 2003).2. Report to Congress, Medicare Contracting Reform,“A Blueprint for a Better Medicare.” February 7, 2005, pp. 9.http://www.cms.hhs.gov/MedicareContractingReform/Downloads/report_to_congress.pdf3. Centers for Medicare & Medicaid Services, MedicareAdministrative Contractor, Workload Implementation Handbook,March 1, 2007, 4.10.1 Local Coverage Determinations, pp. 4-7.4. Medicare Contracting Reform Overview. http://www.cms.hhs.gov/MedicareContractingReform/oncologistics 29
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