Multiple deadlines are available in December to voice your opinion with the Medicare Administrative Contractors (MACs) regarding their announced plans to limit reimbursement for dialysis that occurs more than three times per week exclusively to patients who meet specific acute condition requirements.
Seven MACs covering eight jurisdictions (WPS, Novitas Jurisdiction H, Novitas Jurisdiction J, NGS Jurisdiction K, NGS Jurisdiction 6, Noridian Jurisdiction E, Noridian Jurisdiction F, and First Coast, Palmetto, CGS), covering over half of the country, released nearly identical draft Local Coverage Decisions implementing restrictive guidance related to more frequent dialysis.
Within a very narrow timeframe, the MACs separately announced almost identical plans to limit reimbursement for more frequent dialysis exclusively to patients who meet specific acute conditions outlined in a draft Local Coverage Determination (LCD). These draft LCDs propose that any claim linked to a Plan of Care (POC) that includes dialysis treatments occurring more than three times per week—for any chronic condition or acute condition not included on the list—will be denied.
The American Society of Nephrology (ASN) has been working with a wide range of kidney groups and coalitions, including the Renal Physicians Association, Kidney Care Partners, the Alliance for Home Dialysis, and others to advocate for rejection of the LCDs. ASN asks members to reach out to their respective MACs to voice their concerns.
In comment letters to the MACs, ASN objects to the proposed policy change on the grounds that the change:
5 U.S.C. & 500 et seq.