Local coverage: Change is possible
Q. I would like to change the terms of a local coverage determination (LCD). Is this possible and how?
A. Yes, it is possible. Section 522 of the Benefits Improvement and Protection Act (BIPA) provides for both the creation of LCDs and establishes an "appeals process." Here's what you need to do:
Do business in the DMERC's jurisdiction; clearly identify the language you want added to or deleted from the LCD; submit new evidence that may "materially affect the LCD's content or basis"; and submit the request to the DMERC in writing and include all of your appropriate contact information.
The DMERC has 30 days to determine if your request is valid or invalid and must notify you of that determination. If it is determined to be invalid, the DMERC must explain why.
If the request is considered valid, the DMERC has 90 days to make a reconsideration decision on the request. The DMERC has four options: no revision, revision to a less restrictive policy, revision to a more restrictive policy or retirement of the policy.
Whatever the decision, the DMERC must notify you of its full rationale.
Go to the DMERC's Web site and search for LCD reconsideration process and follow the steps carefully. Good luck!
Michael Watson is vice president of government affairs for American Medical Technologies. Reach him at email@example.com or (707) 542-0330.