Last Modified: 9/4/2018 Location: FL, PR, USVI Business: Part A, Part B
How to submit comments
Draft LCD development process
The Centers for Medicare & Medicaid Services (CMS) instructions regarding development of local coverage determinations (LCD) are outlined in the IOM Publication 100-8, Chapter 13, Section 7. They state that a local coverage determination is a composite of statutory provisions, regulations, nationally published Medicare coverage policies, and local coverage determinations. In the absence of statute, regulations, or national coverage policy, Medicare contractors are instructed to develop LCDs to describe when and how items or services will be covered. LCDs are also developed to clarify or provide specific detail on national coverage guidelines. Local coverage determinations are the basis for medical review decisions made by a Medicare contractor’s medical review staff.
Medical review initiatives ensure the appropriateness of medical care; they also ensure that new local coverage determinations and review guidelines are consistent with accepted standards of medical practice. Several issues are important when developing LCDs:
First, extensive literature research is undertaken to identify how and when the subject matter is utilized by the medical community. Medicare regulations are reviewed to determine areas of limitation and/or noncoverage. The findings are reviewed with the Medicare contractor’s medical director.
Second, draft LCDs are introduced to the provider community. The Contractor’s Advisory Committee (CAC), which includes representatives from physician and other health care professional specialty societies (e.g., nurses, therapists, and medical associations), the Florida Hospital Association (FHA), the Physician Advisory Council, the Quality Improvement Organization (QIO), the beneficiary community, and the Medicare contractor review LCDs. Also, all providers serviced by the contractor receive all new and/or revised LCDs for review and comment. This process provides a 45-day notice and comment period to allow:
• Dissemination of draft LCDs among appropriate health care facility personnel; and
• An opportunity to formulate and share constructive comments and feedback with the Medicare Medical Policy department.
Third, after comments received during the 45-day comment period are reviewed and considered, the final LCD is published to the provider community, usually with 45 days advance notice prior to implementation, through:
• The Medicare A Connection (to the Medicare Part A provider community)
• The Medicare B Connection (to the Medicare Part B provider community)
Drafts for new LCDs are posted to the First Coast’s Medicare draft LCDs for your review and comments. The comment period of 45 days begins on the date indicated in the Start Date of Comment Period section of each draft policy. Written comments pertaining to these LCDs must be received no later than 45 days from this date. No changes will be instituted until comments received during this period have been considered and the LCD finalized.
Please direct all written comments, with documentation to support your position to:
Medical Policy and Procedures Department
P. O. Box 2078
Jacksonville, FL 32231-0048
P. O. Box 2078
Jacksonville, FL 32231-0048
Email to: Medical.Policy@FCSO.com
The Medical Policy and Procedures department appreciates your constructive comments and medical input. In the absence of significant written comments, the LCD will be finalized and published via the Medicare A Connection, the Medicare B Connection, and/or First Coast’s Medicare draft LCDs, with an effective date of 45 days after publication.
For questions regarding local coverage determinations, please call Provider Contact Centers at:
Medicare Part A 888-664-4112
Medicare Part B 866-454-9007
Note, however, that all comments on LCDs must be submitted to the Medical Policy and Procedures department in writing at the above indicated address.
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