Hyperbaric physicians unite! Time to speak out and voice your concerns and educated opinions on the limitations imposed by the First Coast Draft LCD.
GuideWell Source is the parent company of First Coast Service Options as well as Novitas Solutions. Between these two Medicare Administrative Contractors (MAC) they cover over 1/3 of the ENTIRE Part A and Part B Medicare landscape.  If you do not think this will affect you, you are kidding yourself. They are open about trying to have an integrated local coverage determination policy for hyperbaric oxygen therapy. It is not too great a stretch to imagine it being adopted by other MACs.
So, go to the link (https://www.cms.gov/medicare-coverage-database/details/lcd-details.aspx?LCDId=36503&ContrId=370&ver=2&ContrVer=1&name=370*1&bc=AQAAAgAAAAAAAA%3d%3d&), and comment here at this email: [email protected],  Subject: DL36504.
Tell them your experienced and educated opinion about the details of the guidance offered and how this will impact your patients. Read the Draft literally. It will be implemented literally.
How do you feel about:

  1. Being told how to treat Clostridial myositis and myonecrosis, must it be 3.0 ATA for 90 minutes?
  2. Compromised grafts and flaps: HBO therapy has not been found to be of significant benefit post 24 hours of warm ischemia or signs of compromise.
  3. This indication is not for primary management of wounds, maintenance of split thickness skin grafts or bioengineered skin substitutes placed on wounds or operative sites (Mohs).  But the language in the ICD-10 specifically covers skin grafts (see below) but seem to be specifically excluded in the LCD.
  4. ICD-10 language:
    1. T86.820 Skin graft (allograft) rejection
    2. T86.821 Skin graft (allograft) (autograft) failure
    3. T86.822 Skin graft (allograft) (autograft) infection
    4. T86.828 Other complications of skin graft (allograft) (autograft)
  5. Chronic osteomyelitis: Hyperbaric oxygen therapy is not considered medically necessary or appropriate for treatment of osteomyelitis of small or non-weight-bearing bones of the forefoot and fingers (metatarsal bones, phalanges) which are more effectively treated with debridement… Are we advocating for finger amputations, and for immediate transmetarsal or ray amputations?..daily sessions lasting 60-120 minutes up to a maximum of 40 treatments within a 12 month period.
  6. Diabetic Foot ulcers: Transcutaneous oxygen measurements consistent with inadequate local blood flow/ tissue oxygenation expected to affect improvement, when treating diabetic wounds of the lower extremities, may establish lack of medical necessity on review.  If TCOMS are normal they do not qualify, if they are low, they do not qualify, so when do they qualify?

Your input is vital to this process. There are a number of potential concerns in the language of this proposed LCD that may impact your ability to offer quality and appropriate care for your patients. If you have comments, please address them to First Coast, so that they can be acknowledged and potentially addressed. If you say nothing, then you are stuck with whatever comes out in the final policy. These policy changes affect the way you will be able to practice as well as the outcomes of your patients. Impact statements from patients on how HBO has changed their quality of life are also viewed by First Coast.
Dr. Gelly has been involved in hyperbaric medicine and wound care since 1991. Past positions have included Medical Directorships at academic and community hyperbaric medicine and wound care programs. She started a non-hospital affiliated hyperbaric medicine center which was one of the first UHMS accreditated centers. She has been actively involved in billing and reimbursement issues for both facilities and physicians. Until recently, she was the Medical Director of Hyperbaric Physicians of Georgia, a group of physicians dedicated to the practice of hyperbaric medicine and wound healing, with 5 subspecialty boarded physicians in its membership. In addition to lecturing nationally on hyperbaric medicine and wound healing for many years, she was the president of the Gulf Coast Chapter of the UHMS from 2005-2007. Currently, she serves as the Emeritus Medical Director of Hyperbaric Physicians of Georgia, and as C.E.O. for HyperbaRXs.

Caroline Fife, MD
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