July 14, 2017
The Coalition submitted a letter to the DMEMAC medical directors requesting a delay of future surgical dressing LCD (L33831). The Coalition cited the LCD’s flaws in coverage criteria, in violation of current Medicare requirements and congressional intent outlined in the 21st Century Cures Act as significant flaws in the policy. Furthermore, the Coalition states in its comments that proposals in the LCD would eliminate coverage for hydrogel dressings used for stage II ulcers. The LCD includes other coverage restrictions that lack sufficient evidence to support them or that conflict with established standards of care as well.  Finally, the Coalition noted that the LCD does not provide any explanation for prohibiting the use of composite dressings to treat lightly exudative wounds, which also rubs contrary to the standard of care.
Letter Appendix
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