Comments to CGS draft LCD on Skin Substitutes for DFU/VLU
The Coalition submitted comments to Cigna Government Services (CGS) on its draft LCD for Skin Substitutes for the Treatment of Diabetic Foot Ulcers and Venous Leg Ulcers (DL36690) and the accompanying Local Coverage Article addressing Billing and Coding (DA56696). The Coalition voiced concerns that CGS created an LCD/LCA that was virtually verbatim to what was issued by Novitas and First Coast, whose own policies were fraught with clinical inaccuracies and were not supported by current clinical evidence. Specific policy provisions addressed in the Coalition's comments include:
- Application limitation over a 12 week timeframe
- Tissue Reference Group (TRG) letters
- Evidentiary requirements
- Coverage decisions being made in an article
The Coalition recommended that CGS pull the draft policies, then work with stakeholders and its Contractor Advisory Committee (CAC) to craft a more clinically accurate policy that is based on the most currently available evidence so that patient care will not be negatively impacted.
Read Coalition Comments
