Monitor the local coverage determinations (LCD) that impact your practice even if an LCD or companion billing article has just emerged from a cycle of proposed LCD, public comment, and final version. And to make sure practices stay on their toes, MACs frequently backdate the changes.
The uniform policies for epidural steroid injections for pain management that went into effect late last year illustrate that LCDs are works in progress that change without warning. Five Medicare administrative contractors (MACs) have revised the uniform LCD that they recently released and more changes could be on the horizon.
For example, the new LCD went into effect Dec. 5, 2021, for practices covered by
Palmetto GBA and
CGS Administrators. The Medicare administrative contractors (MAC) quickly revised the companion billing article by deleting code
M48.061 (Spinal stenosis, lumbar region without neurogenic claudication) from the list of covered diagnosis codes and clarifying the utilization parameters by replacing the word “anatomic” with “spinal” to describe the regions that could be treated in a rolling 12-month period:
No more than 4 epidural injection sessions (CPT codes 62321, 62323, 64479, 64480, 64483, or 64484) may be reported per anatomic spinal region in a rolling 12-month period regardless of the number of levels involved.
The MACs backdated the revisions to the LCD’s effective date.
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The LCD for practices covered by
National Government Services (NGS) also went into effect Dec. 5, 2021. The MAC made the same changes to its billing article but its updates went into effect Dec. 30, 2021.
The LCD that went into effect Dec. 12, 2021 for practices covered by
First Coast Service Options (FCSO) and
Novitas was revised Jan. 20 to correct what the MACs described as a typographical error in the section on steroid dosing. That correction – the removal of dosing information for methylprednisolone, which has a black box warning for epidural injections – was backdated to Dec. 12, 2021.
LCD revised and published on 01/20/2022 effective for dates of service on and after 12/12/2021 to revise ‘bullet #12’ in the ‘Limitations’ section to: Steroid dosing should be the lowest effective amount. It is recommended not to exceed 80 mg of triamcinolone, 12 mg of betamethasone, or 15 mg of dexamethasone per session.
Amy Turner, RN, BSN, MMHC, CPC, CHC, CHIAP, director, advisory solutions, Ventra Health, pointed out that the drug was not included in the final LCDs that had been released the other MACs
during a Nov. 30 webinar about the new LCD hosted by FCSO and Novitas.
Stand by for more updates.
Novitas,
FCSO and
WPS GHA have not updated their billing articles to delete M48.061 or update the utilization parameters, and Noridian has not released its final LCD.
Stealth updates aren’t the only pitfall created by the new uniform LCD for epidural steroid injections, or the uniform LCD for facet joint interventions that went into effect.Turner has identified several flaws in the charts she reviews for these services, including documentation of conservative care that does not meet the new LCDs’ standards.