Last night the Centers for Medicare & Medicaid Services (CMS) released the long awaited Lower Limb Prosthetic Workgroup Consensus Document (Consensus Document). This document was the product of the Lower Limb Prosthetic Interagency Workgroup that was created in response to the backlash from the Proposed/Draft Local Coverage Determination (LCD): Lower Limb Prostheses (DL33787) originally released in July 2015.
In 2015, after significant push back from the limb loss community, the interagency workgroup was created. For those of you who remember three years ago, the response from the community was overwhelming: over 100,000 signatures on a White House petition, tens of thousands of formal comments submitted and a public hearing so packed it had to be moved to a larger space.
Today we got the news we waited nearly three years for: Medicare’s Interagency Workgroup is providing “instruction to its Durable Medical Equipment Medicare Administrative Contractors (DME MACs) to remove the proposed/draft Local Coverage Determination (LCD): Lower Limb Prostheses.”
This is another significant win for the limb loss community and means that Medicare’s coverage for lower limb prostheses will continue under the current coverage determination.
This document moves the discussion in a promising direction but there is still work all of us need to do. While there are many positive recommendations in the Consensus Document, there are also details that the Amputee Coalition will pursue for further discussion. This includes:
- the continued reliance on physicians in documentation and medical necessity determinations without providing further guidance for recognition of the prosthetist’s notes,
- concerns about coverage impacts for people who may benefit from an elevated vacuum suspension system or powered ankle technology,
- the need to collaborate with CMS, the National Center for Medical Rehabilitation Research (NCMRR) and others to advance outcomes research and to consider a National Coverage Determination (NCD) to address whether people at a K2 activity level would benefit from use of a microprocessor knee,
- the potential issues around and timeline for a pre-authorization process, and
- process clarification on replacing a prosthetic component less than three years of age.
The Amputee Coalition will assess, gather comment, provide and publicly share a formal response to the Consensus Document.
At its heart, the Amputee Coalition believes that a patient-centered approach with support and guidance from all members of the medical team ensures the best outcomes. The individual should always be at the center of healthcare decisions and along with research, personal stories and experiences should also help shape policies moving forward.
As we continue efforts in this area we want to hear your story. Please visit http://www.amplifyyourself.org to build the base of support and information to ensure your needs are met fully and well.
In summary, the determination to retire the proposed LCD is welcomed and appreciated, but we will continue to push for improved access to care for people with limb loss. The Amputee Coalition looks forward to working with CMS, NCMRR and other federal agencies and external partners to collaborate on ways to improve patient access and care and focus on outcomes based research.
Jack D. Richmond
President and CEO
P.S. If you would like to read the Consensus Document summary, you can find it here: https://www.cms.gov/Medicare/Coverage/DeterminationProcess/downloads/LLP_statement.pdf
To read the full report, click here: https://www.cms.gov/Medicare/Coverage/DeterminationProcess/downloads/LLP_Consensus_Document.pdf