Head spinning from Medicare Listservs?

Don't worry, Jillian has your back!

The NCDs and LCDs for which clinical indications have been suspended now include:

  • Positive Airway Pressure Devices for the Treatment of Obstructive Sleep Apnea (L33718);  (the NCD 240.4 for PAP devices was on the list before, but they added the LCD in this email as well)

  • Oral Appliances for the Treatment of Obstructive Sleep Apnea (L33611)

  • Mechanical In-exsufflation Devices (L33795)

  • High Frequency Chest Wall Oscillation (L33785)

  • Nebulizers (L33370)

  • Glucose Monitors (L33822) – Only clinical indications for Therapeutic Continuous Glucose Monitors (CGM) are not enforced

They also provided additional information about what this actually means since it wasn’t really clear before:

Treating practitioners and suppliers must still:

  • Provide a standard written order (SWO) for all items. For PMDs, the treating practitioner must document and communicate to the DMEPOS supplier that the treating practitioner has had a face-to-face encounter with the beneficiary within the 6 months following the face-to-face evaluation preceding the date of the written order/prescription, per section 1834(a)(1)(E)(iv) of the Act;

  • Ensure that the items or services are reasonable and necessary;

  • Continue documenting the medical necessity for all services. Accordingly, the medical record must be sufficient to support payment for the services billed (that is, the services were actually provided, were provided at the level billed, and were medically necessary);

  • Make documentation available, upon request.

This enforcement discretion will only apply during the COVID-19 PHE. At the conclusion of the COVID-19 PHE, the DME MACs will return to enforcement of the clinical indications for coverage.

Updates from CGS also stated later on that they should include the CR modifier and enter “COVID-19” in the Claim Note on claims where clinical indications were not obtained due to COVID. 

Sourced from: CGS, DME MAC Jursidiction B News from CMS (CMS-1744-IFC & CMS-5531-IFC)

~by Jillian Miller