Prior Authorization for Lower Limb Prosthetics - JA DME

Due to the CMS final rule 42 CFR §§405 and 414., in 2016, a Condition of Payment Prior Authorization (COPPA) process for certain DMEPOS that are frequently subject to unnecessary utilization was established. In November 2019, CMS standardized regulations regarding Prior Authorization (PA) to create a Master List of DMEPOS that can be subject to PA and/or a Face-to-Face encounter and a Written Order Prior to Delivery.

Lower limb prosthetics (LLP) joined the COPPA program September 1, 2020.

Prior Authorization Timelines

Access the below related information from this page.

• 2020 Expansion
• Documentation to Include in Submission
• Methods of Submission
• Expedited Request Guidelines
• Avoid Request Rejections
• Affirmative and Non-Affirmative Decisions
• Decision Letters
• Top Reasons for Non-Affirmation
• Still Have Questions?
• Resources

2020 Expansion

• Effective for dates of service on/after December 1, 2020, Prior Authorization is required nationwide.
• PA is required for six LLP HCPCS codes:
  • L5856 ADDITION TO LOWER EXTREMITY PROSTHESIS, ENDOSKELETAL KNEE-SHIN SYSTEM, MICROPROCESSOR CONTROL FEATURE, SWING AND STANCE PHASE, INCLUDES ELECTRONIC SENSOR(S), ANY TYPE
  • L5857 ADDITION TO LOWER EXTREMITY PROSTHESIS, ENDOSKELETAL KNEE-SHIN SYSTEM, MICROPROCESSOR CONTROL FEATURE, SWING PHASE ONLY, INCLUDES ELECTRONIC SENSOR(S), ANY TYPE
  • L5858 ADDITION TO LOWER EXTREMITY PROSTHESIS, ENDOSKELETAL KNEE SHIN SYSTEM, MICROPROCESSOR CONTROL FEATURE, STANCE PHASE ONLY, INCLUDES ELECTRONIC SENSOR(S), ANY TYPE
  • L5973 ENDOSKELETAL ANKLE FOOT SYSTEM, MICROPROCESSOR CONTROLLED FEATURE, DORSIFLEXION AND/OR PLANTAR FLEXION CONTROL, INCLUDES POWER SOURCE
  • L5980 ALL LOWER EXTREMITY PROSTHESES, FLEX FOOT SYSTEM
  • L5987 ALL LOWER EXTREMITY PROSTHESIS, SHANK FOOT SYSTEM WITH VERTICAL LOADING PYLON
• Effective for claims on/after January 1, 2021: the only products which may be billed using the above HCPCS codes are those for which a written coding verification review (CVR) has been made by the Pricing, Data Analysis, and Coding (PDAC) contractor and subsequently published on the appropriate Product Classification List. See the PDAC website for additional details.

Documentation to Include in Submission

• Standard Written Order
• Documentation from the medical record to support medical necessity
• Prosthetist records
• Documentation must be submitted to the appropriate jurisdiction based on the beneficiary's permanent address with the PA coversheet for fax, mail, or electronic submission of medical documentation (esMD). For Noridian Medicare Portal (NMP) submissions, complete all required fields in the portal as a coversheet is not required.
• Indication of quantity and side of prosthetic component:
  • On PA Request cover sheet or
  • Portal, a coversheet is not required however, the order and/or medical record will need to indicate the number of prosthetic components that were ordered including right, left or both right and left prosthetic needed
• PDAC Verification

To ensure process efficiency, assure all components are completed and included within the submission.

Note: Suppliers are reminded that Section 1834(h)(5) of the Act states that for purposes of determining the reasonableness and medical necessity of orthotics and prosthetics, documentation created by orthotists and prosthetists shall be considered part of the individual's medical record to support documentation created by eligible professionals as described in section 1848(k)(3)(B) of the Act.

Documentation from a face-to-face encounter conducted by a treating practitioner, as well as documentation created by an orthotist or prosthetist becomes part of the medical records and if the orthotist or prosthetist notes support the documentation created by eligible professionals described in section 1848(k)(3)(B), they can be used together to support medical necessity of an ordered DMEPOS item. In the event the orthotist or prosthetist documentation does not support the documentation created by the eligible professional, the DME MAC may deny payment.

Methods of Submission

• Noridian Medicare Portal (NMP)
  • A coversheet is not required for NMP submission
• Fax
• Mail
• Electronic Submission of Medical Documentation (esMD)

Expedited Request Guidelines

In very rare emergent circumstances, an expedited review may be requested. To be processed as an expedited request, circumstances must be in accordance with the following guidelines:

• Expedited request must be accompanied by supporting medical documentation
• Physician clearly indicates, with supporting rationale, that the 10-business day timeframe for an initial decision could jeopardize the beneficiary's life or health

When documentation does not support the above guidelines, expedited requests will be downgraded to standard requests.

Avoid Request Rejections

There are various reasons why a PA may be rejected and not reviewed. Proper completion of the PA coversheet or information not entered in portal and a thorough intake process aids in minimizing most rejections. Common reasons include:

• HCPCS code is not subject to PA
• Duplicate to a previous PA request
• Request sent to the incorrect jurisdiction based on the beneficiary's permanent address

Affirmative and Non-Affirmative Decisions

After the PA submission goes through the medical review process, the supplier will receive a decision letter.

Decision Letters

Treating practitioners involved in the submission of a PA may request a copy of the decision letter.

• The treating practitioner requesting the letter must be able to demonstrate a legitimate, specific need for the information requested
• Request may be sent in with PA request or separately

Still Have Questions?

Call the Supplier Contact Center or Interactive Voice Response (IVR), or Pre-Claim Hotline.

Resources

• CMS Internet Only Manual (IOM), Publication 100-08, Medicare Program Integrity Manual