The Alliance submitted a follow-on letter to CMS and its National Correct Coding Initiative (NCCI) Contractor continuing to urge consideration of our requests for edits. While through our advocacy efforts we successfully achieved an update to the NCCI manual in 2021 allowing for debridement and compression to be provided on the same day, the correlating changes to the edits table were not made at that time. The Aliance has again advocated for this change, emphasizing that "making this change without deleting the corresponding procedure-to-procedure edits does not sufficiently address the problem of Medicare beneficiaries being denied access to these important, limb and life-saving services. With the edits still in place, providers are discouraged from performing both services when performed on the same limb, despite the fact they are completely separate services with no overlap in the time, work, effort, or risk associated with the performance of the two. Making the above changes without deleting the corresponding procedure-to-procedure edits has caused confusion [and] uncertainty regarding how to interpret this." Together with the letter the Alliance submitted a table of the existing edits and our requested corrections so that the language in the Policy Manual be consistent with the edit table.

Read More