Ask the DMERC MDs
Q. I've heard the DMERCs may release a Draft Local Coverage Determination (LCD) for power wheelchairs this summer. What is an LCD? How am I supposed to respond to this?
A. Local Coverage Determination is the term currently used to describe the document that was formerly known as Medical Review Policy. Over the past few years, the format and terminology has been changed to comply with legislative requirements. However, the LCD together with the Policy Related Article still contains the coverage, coding and documentation requirements applicable to a given item.
As we develop an LCD, our goal is to identify criteria that describe when the item is reasonable and necessary and thus eligible for reimbursement. We use an Evidence Based Medicine approach to determine the standards used. To accomplish this we survey and review the relevant published clinical literature and consult with recognized experts in the field. After extensive research and discussion we create a Draft LCD for release during a public review and comment period. During the comment period we solicit feedback from any interested party on the LCD. The information received is then reviewed and the policy is modified as needed. The LCD is then finalized and published.
The comment period is an important element in the LCD development process. It provides an opportunity for a real-world test of the concepts contained in the draft. Many times important modifications to the LCD are made based upon information provided by commenters. We strongly encourage participation in this phase of LCD development. If you disagree with any aspect of the policy, you should be very specific and, if possible, offer an alternative indication, guidelines, etc. Please provide a clinical rationale for your position. If comments relate to medical necessity criteria, you should include references from the published clinical literature (e.g. standard textbooks, peer-reviewed journals, etc.). We also encourage a written response if you agree with the policy Instructions on how to comment are included with each draft LCD release.
We would remind suppliers not to use the information in a draft LCD in the course of daily business. The content can and does change between the draft and final versions. Wait for the publication of the final LCD and note the effective date.
If you have a question that's both timely and nationally relevant, e-mail your question to firstname.lastname@example.org. The medical directors are Paul Hughes, M.D. (Region A), Adrian Oleck, M.D. (Region B), Robert Hoover, M.D. (Region D) and Stacey Brennan, M.D. (Region C).