I have received many emails about the newly released Wound Care Local Coverage Determination (LCD) released by Novitas, the Medicare Administrative Carrier (MAC) for the following states: Colorado, New Mexico, Oklahoma, Texas, Arkansas, Louisiana, Mississippi, Delaware, District of Columbia, Maryland, New Jersey, and Pennsylvania.
The Novitas Wound Care LCD will become effective for services performed on or after 11/09/2017.
You can find a pdf version of the LCD here.
I will address some of the concerns that have been expressed in emails to me. However, it’s important to know that the final Novitas LCD was vastly improved over the draft LCD thanks to the combined advocacy of many organizations under the umbrella of the Alliance of Wound Care Stakeholders. The Alliance participated in the January 2017 public meetings and submitted written comments in March 2017. I hope you will go to the link below on the Alliance website and read the comment letter which had to be prepared over a very short time frame.
As you read the detailed comment letter prepared by the Alliance in response to the Novitas proposed rule, remember that the people who respond to these LCDs are clinicians just like you who, after a busy day seeing patients, spend countless late nights looking up references and wordsmithing these letters.
It is gratifying that Novitas seriously considered the Alliance comments and made many changes to the final policy in response to the Alliance member efforts. The Alliance communicated directly with the Novitas Medical Directors, Drs. Patterson and Lalla, who seemed appreciative for the thoughtful input they received.
This is a big topic to cover, but here are a few “wins” in the final LCD compared to the draft:
- There is now more flexibility in performing debridements and NPWT.
- There is coverage for disposable NPWT.
- Novitas eliminated the language in which wound volume or surface dimensions needed to decrease by 10% per month or 1 mm/week.
- There is now coverage for Palliative (Wound) Care, and
- Several areas in which clinically inaccurate information was placed in the draft policy were corrected in the final policy.
Everyone should review the final LCD, even if you are not in a state covered by Novitas. Novitas policies tend to act as a bellweather for the other MACS. Even though it is not perfect, I would call this a success story for advocacy through the Alliance.
There are a lot of specific issues in the Wound Care LCD that are worth discussing. Because the topic is so big, I will break it into several blogs. I’d like to tie a lot of threads together in this discussion, starting with the Value in Health article that just came out on the cost of chronic wound care, performed by the Alliance and published open source so that a complete copy is available to you here:
What we learned from the Value in Health study (see Table 4) is that the largest portion of Medicare costs for wound care are in the outpatient setting and in 2014 alone, Medicare spent (at a minimum) $9.9 Billion dollars on outpatient wound care. However, $35.8 Billion is the high estimate for outpatient wound care costs. It is possible that the high estimate is the more accurate one because the mechanism of outpatient billing makes it easier to determine whether charges were related to a specific wound diagnosis.
How does the Novitas LCD link to the Value in Health article on the cost of chronic wound care? Even though Medicare has not had accurate figures on the total cost of chronic wound care, due in part to the broad scope of diagnoses and procedures involved, for more than a decade, data have been accumulating that suggest overutilization of some wound care services. The MACs have only a blunt tool available to curtail over utilization, if they believe that it occurs, and that is to simply put limits on covered services. Next I will talk about the history of this issue.