January 26, 2017
The Coalition provided oral testimony to Novitas Solutions during its public meeting on wound care draft LCD (DL35125). The Coalition’s comments focus on the drastic difference between the draft LCD compared to its original and that Novitas gives no clear indications as to the reasons for this change. The Coalition also cited specific issues with the arbitrary and non-evidence based utilization parameters for disposable Negative Pressure Wound Therapy. Finally, the Coalition expressed its concerns regarding the confusing and contradictory information contained throughout the LCD, stating that the LCD must be changed and clarified before finalization.
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