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Linda Collins Blogger

Draft LCD for Lower Limb Prostheses: How to Comment

Posted by Linda Collins | July 21, 2015

​Last week the DME MACs released a new draft LCD for lower limb prostheses that could replace the current one. The ramifications are potentially far reaching. It is not an exaggeration to say that this might be the most significant change to prosthetic billing and coverage requirements since the creation of the L codes if the draft were implemented in its current form.

What does this mean for you?

If implemented, these changes could have a profound impact on how you code certain items and how your business operates. We therefore recommend you do 3 things immediately.

First, review the draft LCD in its entirety. (See Huge Changes for Prosthetics?) While we think that the ones we have discussed in the post are among the most important, it is possible that other changes could have a particularly significant impact on your specific business.

You can link to the draft LCD here - . (In the interest of simplicity, we are not linking to each individual DME MAC because the draft LCD is identical for all 4 Regions.)

Second, after you identify the potential changes that you think could have the biggest effect on your business, do hard research based on your historical practices to try to quantify their impact. It's not enough to say, "These X things will make things more difficult for us!" You have to then model the potential ramifications so that you can develop appropriate contingency plans.

Third, make sure to closely follow key O&P organizations like NAAOP and AOPA to see how you and your patients can participate in the draft LCD comment process.

The MACs are taking comments on the draft LCD until August 31st. You should be specific in your comments and offer clinical rationale. Include references from published literature. Submit your comments electronically at the email address below:

Stacey V. Brennan, M.D., FAAFP

Medical Director, DME MAC, Jurisdiction B

National Government Services

8115 Knue Rd

Indianapolis, IN 46250-1936

You may read the full instructions for comments here.

Stay tuned to Össur R&R for additional information as it becomes available.

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