May 09, 2019

CMS Releases Guidance for Understanding Revised LCD Procedures

The Centers for Medicare and Medicaid Services (CMS) has revised the Medicare Program Integrity Manual (PIM), Chapter 13 – Local Coverage Determinations (Pub 100-08) to reflect extensive process changes for local coverage determinations (LCDs) implemented in January 2019.

Nearly all aspects of the LCD process were modified. The manual revisions describe changes to the LCD process, what to expect and how to provide feedback to Medicare Administrative Contractors (MACs). It also clarifies CMS’s expectations for MACs.

MACs are organizations that have statutory authority to develop LCDs for their individual jurisdictions. Chapter 13 of the PIM outlines the LCD process, which serves as a roadmap for MACs. The new process provides greater transparency, consistency and patient engagement while supporting larger CMS innovation-related initiatives.

We encourage ACR members to review the FAQ document to clarify how MACs are implementing new processes for LCDs and their engagement with stakeholders. Key questions from the document include but are not limited to the following:

  • Why was Chapter 13 of the PIM updated?
  • What specific statutory mandates of the 21st Century Cures Act of 2016 (Public Law 114-255) apply to Medicare’s revised LCD process?
  • What other major changes were made to the PIM chapter 13?
  • Is a CAC required for every LCD reconsideration or new LCD?
  • Can MACs have multi-jurisdictional open meetings?
  • When can the public expect to see the LCD content changes outlined in the new PIM?
  • Will the relocation of codes from LCDs to articles impact the availability of downloadable LCD data that is available in the Medicare Coverage Database?

Questions related to changes on the LCD process may be directed to Alicia Blakey at ablakey@acr.org.