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BIAA Action Alert: Protect Lower Limb Prostheses

20-Aug-2015 Medicare's New Draft Local Coverage Determination (LCD) for Lower Limb Prostheses sends amputees back to 1970's standards of care and includes multiple, alarming policy changes proposed by CMS contractors that dramatically restrict access to prosthetic limbs. While this issue is specific to Medicare-covered prostheses, it has broader procedural implications on all payers and sets a precedent for future coverage of all assistive devices and technologies.

On July 16, 2015, the four Durable Medical Equipment Medicare Administrative Contractors (DME MACs) released a proposed draft LCD for Lower Limb Prostheses that is highly restrictive and eviscerates the current standard of prosthetic care. Many of the proposed changes will impact all amputees using prostheses covered by all payers, including the VA. The draft LCD raises serious concerns for patients, prosthetists, physicians, and other health care providers and suppliers caring for patients with lower limb amputations. 

This is a dangerous precedent, that could easily be replicated to restrict Medicare coverage regarding other assistive devices and technologies.

A "We the People" petition was established on July 31stand garnered 100,000 signatures by August 17th, which triggers an obligation for the White House to respond to the petition. The petition seeks rescission of the Proposed LCD. White House staff has said it is the first time a disability-related petition has breached the 100,000 signature mark.

What You Can Do To Help?
 
1.  Attend/Participate in the Public Meeting: There will be a public meeting held by the DME MACs on Wednesday, August 26th  from 8:00 a.m. EDT to 12:00 p.m. EDT.  To either attend or participate by phone, you must register by Friday, August 21st. Visit http://www.saveprosthetics.org/ to register to attend in person, participate by phone, and speak if you would like.
 
2.  Submit Comments and Get on Record: All organizations and individuals are encouraged to submit their own comments to the proposed LCD by August 31st. This will ensure that the Medicare program hears widespread opposition to the Draft LCD. Template letters and other materials to assist in commenting can be found at http://www.saveprosthetics.org/. Comments on the LCD are submitted via email to: DMAC_DRAFT_LCD_Comments@anthem.com.

3.  Rally at HHS in DC: A public rally protesting the draft LCD will occur on Wednesday, August 26th from 2:00-5:00 p.m. EDT outside of the U.S. Department of Health and Human Services: 200 Independence Avenue, SW, Washington, DC  20201. All interested parties are encouraged to attend for all or part of the rally.

This new LCD's comprehensive changes to coverage, coding and payment of lower limb prostheses will drive practice in the future and severely limit access to modern prosthetic technology and the current standard of care.  The LCD was released with virtually no evidence cited for these major changes.  The message to CMS is to rescind the Draft LCD and begin a dialogue with stakeholders to address the concerns with CMS has with this benefit. Please take action today!


 
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