The Alliance submitted comments to CGS Administrators proposed LCD “Non-Invasive Vascular Studies" (DL34045), flagging areas of the policy that are not reflective of current practice or standards of care. Comments addressed a range of issues in the wording of the policy including: inconsistencies in the descriptions of providers permitted to order/perform non-invasive vascular studies, credentialing definitions, accreditation standards and documentation burdens. 

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