LCD Reference Article Response To Comments Article

Response to Comments: Micro-Invasive Glaucoma Surgery (MIGS)

A57893

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Draft Articles are works in progress and not necessarily a reflection of the current billing and coding practices. Revisions to codes are carefully and thoroughly reviewed and are not intended to change the original intent of the LCD.

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Source Article ID
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Article ID
A57893
Original ICD-9 Article ID
Not Applicable
Article Title
Response to Comments: Micro-Invasive Glaucoma Surgery (MIGS)
Article Type
Response to Comments
Original Effective Date
12/26/2019
Revision Effective Date
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Revision Ending Date
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Retirement Date
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Article Text

The comment period for the Micro-Invasive Glaucoma Surgery (MIGS) DL37531 Local Coverage Determination (LCD) began on 10/7/19 and ended on 11/21/19. The comments below were received from the provider community. The notice period for L37531 begins on 12/26/19 and will become effective on 2/10/20.

Response To Comments

Number Comment Response
1

A comment was submitted on behalf of Ivantis, Inc., manufacturer of the Hydrus® Microstent. This comment pointed out an error in the indication statement involving their product. The draft policy currently reads, “The iStent®, iStent inject®, and Hydrus® are FDA approved for use in combination with cataract surgery to reduce IOP in adults with mild or moderate open angle glaucoma (OAG) and a cataract that are currently being treated with medication to reduce IOP”. The statement that accurately reflects the FDA indication is, “The Hydrus® Microstent is indicated for use in conjunction with cataract surgery for the reduction of intraocular pressure (IOP) in adult patients with mild to moderate primary open-angle glaucoma (POAG).”

The LCD language will be revised as follows:

“The Hydrus® Microstent is indicated for use in conjunction with cataract surgery for the reduction of intraocular pressure (IOP) in adult patients with mild to moderate primary open-angle glaucoma (POAG). The iStent® and iStent inject® are FDA approved for use in combination with cataract surgery to reduce IOP in adults with mild or moderate open angle glaucoma (OAG) and a cataract that are currently being treated with medication to reduce IOP”.

2

Glaukos, the manufacturer of iStent® and iStent inject® submitted additional educational material and studies addressing the efficacy of their products. It was also stated that they supported Palmetto GBAs coverage of more than one stent per eye and acknowledged that discussion of coding and pricing of the services does not have a place in comments addressing a draft coverage policy.

Palmetto GBA appreciates Glaukos’ support and comments and agrees that the discussion of coding and pricing is not within the scope of comments on a LCD that addressed only coverage policy. This is especially true now that at the request of CMS, all coding and billing information will be migrated to companion local coverage articles (LCA’s) as of January 1, 2020.

3

Nine comments were received from practitioners referencing coding and pricing of CPT® 0191T and CPT® 376T.

Palmetto GBA appreciates the feedback from Palmetto GBA’s providers; however, coding will no longer be contained within the LCD as of January 1, 2020 and thus becomes an issue separate from the coverage LCD comment process. Pricing of contractor priced codes is also an entirely separate issue from the coverage LCD comment process.

4

A provider submitted a reconsideration request for the addition of several codes to the LCD companion coding and billing article.

The codes requested constitute an expansion of the current coverage provided in the active LCD and this draft. Per IOM-08, Chapter 13, expansion of LCD coverage requires a formal reconsideration request which cannot be acted upon for policies currently in draft.

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Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
Related Local Coverage Documents
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Public Versions
Updated On Effective Dates Status
12/18/2019 12/26/2019 - N/A Currently in Effect You are here

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