Comments on Novitas and FCSO Draft LCD/LCA for Skin Substitutes for the Treatment of DFU/VLU
When Novitas and First Coast Service Option re-issued for comment draft LCDs (DL35041 / DL36377) and LCAs (DA54117 / DA57680), the Alliance questioned why little previously-provided stakeholder input was reflected in the re-posted policies. “We identified many issues in our oral testimony given at April and August 2022 public meetings and in our extensive comments dated May 27. Therefore, it is baffling that First Coast and Novitas have reissued the same draft policies – without taking into consideration ANY of our or other stakeholders’ comments,” the Alliance wrote in its most recent comments submitted to the MACs in September The Alliance again took issue with the shift of 40+ products from the covered to non-covered list, flagged numerous clinical inaccuracies, and recommended that the MACSs withdraw these draft LCD/LCAs and work with their Carrier Advisory Committees (CACs) and stakeholders to craft a more accurate policy.
