Draft Policies Release for Comment Bulletin Article

The Centers for Medicare & Medicaid Services (CMS) assigned to the Durable Medical Equipment Medicare Administrative Contractors (DME MACs) the task of developing local coverage determinations (LCDs) for processing and reviewing Medicare claims for Durable Medical Equipment, Prostheses, Orthoses, and Supplies (DMEPOS). The DME MACs are proposing two revised LCDs and one new LCD. These LCDs require a 45-day public comment period. The comment period for these LCDs begins on Thursday, July 16, 2015 and ends at Close of Business (COB) on Monday, August 31, 2015.

The summaries below highlight only the major points in each LCD. Each draft LCD should be completely reviewed prior to the preparation of comments. 

External Infusion Pumps (revision to existing LCD)

  • Revises the criteria for reimbursement of intravenous inotropic medication

Bowel Management Devices (new LCD)

  • Provides information necessary for processing claims for these technologies based upon their benefit category coverage status.

Lower Limb Prostheses (revision to existing LCD)

  • Revises coverage for the provision of definitive prosthetic components in lieu of  an immediate or preparatory prosthesis
  • Implements a requirement for an independent medical exam to determine functional status
  • Implements a requirement for a new amputee to participate in a rehabilitation program prior to the provision of a definitive prosthesis.
  • Revises functional level modifiers (K-level modifiers)
  • Revises codes for prosthetic feet

We are soliciting comments on these draft policies from physicians, manufacturers, suppliers and other professionals involved in the ordering of provision of these items. For the External Infusion Pump policy, we are only soliciting comments regarding the revised criteria for the reimbursement of intravenous inotropic medications.

We recommend that you distribute these draft policies to selected members of your organization for review and comment. If you disagree with any aspect of a policy, you should be very specific in your comment and, if possible, offer an alternative. You should provide a clinical rationale for your position including references from the published clinical literature (e.g. standard textbooks, peer-reviewed journals, etc.). We encourage a written response if you agree with this policy.

If you are providing comments on more than one LCD, please provide a separate communication for each policy with the policy indicated in the subject line of the submission.

All comments will be collected at a single point of contact. Please submit your comments electronically to the DME MAC medical director at the e-mail address below no later than Close of Business (COB) on the date indicated above for close of the comment period for the applicable LCD. 

Stacey V. Brennan, M.D., FAAFP
Medical Director, DME MAC, Jurisdiction B

National Government Services
8115 Knue Rd.
Indianapolis, IN 46250-1936


The comment process requires a public meeting. A joint DME MAC public meeting will be held on August 26, 2015, from 08:00 AM EDT until 12:00 PM EDT at:

Airport Square Business Park,
1304 Concourse Drive,
Linthicum, MD 21090 

Interested parties from any DME MAC jurisdiction may attend this public meeting. This meeting provides the opportunity for brief oral presentations only. There is no Question and Answer or discussion period as a part of the meeting. In order for oral presentation comments to be considered, they must be presented through the formal comment process. 

Advance registration is required for attendance at the public meeting and the registrant must indicate whether participating as a presenter or attendee (listen only). Registration is online at:


This registration must be completed no later than COB Friday, August 21, 2015. Registrants must include their name, contact information, organization, whether attending in person or via teleconference and the policy(s) upon which oral presentations will be made in their registration information. 

The amount of time allotted to presentations is based upon the number of registered speakers. There shall be one presentation per company or organization. The DME MAC medical directors reserve the right to limit speakers and time as appropriate. Speakers should be prepared to adjust the length of their presentation depending upon the number of speakers. 

*IMPORTANT REMINDER* Suppliers/providers are cautioned not to make any changes to business practices based upon the information contained in these draft documents. Drafts are often substantially revised based upon the comments received. When all comments have been reviewed, revisions will be considered. The final policies will be published in the CMS Medicare Coverage Database and on individual DME MAC websites, allowing for adequate notice before the policies' effective date.

Refer to each DME MAC web site for additional information about policy development and copies of the draft LCDs.

Jurisdiction A - http://www.medicarenhic.com/

Jurisdiction B - http://www.ngsmedicare.com/

Jurisdiction C - www.cgsmedicare.com/jc

Jurisdiction D - http://med.noridianmedicare.com/web/jddme

Thank you for your participation in our policy revision process.


Stacey V. Brennan, M.D., FAAFP

On behalf of:

Wilfred Mamuya, MD, PhD
Medical Director, DME MAC, Jurisdiction A
NHIC, Corp.
75 Sgt. William B. Terry Drive
Hingham, MA 02043-1518

Robert D. Hoover, Jr., MD, MPH, FACP
Medical Director, DME MAC, Jurisdiction C
CGS Administrators, LLC
2 Vantage Way
Nashville, TN 37228-1504

Stacey V. Brennan, M.D., FAAFP
Medical Director, DME MAC, Jurisdiction B
National Government Services
8115 Knue Rd.
Indianapolis, IN 46250-1936

Eileen M. Moynihan, MD, FACP, FACR
Medical Director, DME MAC, Jurisdiction D
Noridian Healthcare Solutions
900 42nd Street South
Fargo, ND 58103-2146


            Last Updated Wed, 15 Aug 2018 09:29:33 +0000