LCD Reference Article Response To Comments Article

Response to Comments: Blepharoplasty, Blepharoptosis Repair and Surgical Procedures of the Brow

A58587

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Article ID
A58587
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Article Title
Response to Comments: Blepharoplasty, Blepharoptosis Repair and Surgical Procedures of the Brow
Article Type
Response to Comments
Original Effective Date
02/04/2021
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First Coast and Novitas Solutions received comments from representatives of the Florida Society of Ophthalmology, Texas Ophthalmological Association and the Oklahoma Academy of Ophthalmology. The following are the comment summaries and contractor responses for Novitas Solutions/First Coast Proposed Local Coverage Determination (LCD) DL35004 /DL34028 Blepharoplasty, and Surgical Procedures of the Brow which was posted for comment on September 24, 2020, and presented at the October 2020 Open Meeting. All comments were reviewed and incorporated into the final LCD where applicable.

Response To Comments

Number Comment Response
1

One commenter noted that there is no general consensus that visual field in any way aids in medical necessity determination as Blepharoplasty/Ptosis. Photographs are subjective and can easily be altered. Good quality external photographs that show the pathology of a Ptosis or Pseudoptosis with and Margin Reflex Distance (MRD1) of 2 mm or less is the gold standard and is objective. A visual field test is not a valuable measurement in the determination of medical necessity for Blepharoplasty/Ptosis repair.

Thank you for your comment. We agree that visual field testing is not a requirement but may be one of the assessments used by the provider which may support the medically reasonable and necessary for Blepharoplasty/Ptosis repair.

2

The inclusion of eyelid edema, tumor or mass eyelid lesions are covered in other eyelid procedures and should not be included in this LCD for entropion or ectropion.

Thank you for your comment. The literature supports blepharoplasty surgery for correcting lower eyelid ectropion as result of edema, mass or tumor. As summarized in the LCD, Bartley et al supports that blepharoplasty includes procedures to repair ptosis, eyelid retraction, entropion, ectropion, trichiasis, or defects after excision of tumors. Review of evidence provided by Guthrie and colleagues describe mechanical ectropion which occurs secondary to an eyelid mass or tumor. A large amount of lower eyelid edema, especially in middle age or elderly, masses and tumors causing stretching and redundancy of lower eyelid tissue are supported in the literature as secondary causes of ectropion. There will be no change to the LCD.

3

It is recommended to add the following Current Procedural Terminology (CPT) procedure codes for the indication of Entropion: 67921, 67922, 67923, 67924 and 67961 and the following CPT procedure codes for the indication of Ectropion: 67914, 67915, 67916 and 67917.

Thank you for your comment. After review, the related Billing and Coding Article for the LCD will be revised to include the following CPT procedure codes: 67914, 67915, 67916, 67917, 67921, 67922, 67923, 67924 and 67961.

4

First Coast received comment recommending a change of the title of the LCD to "Blepharoplasty, Blepharoptosis Repair and Brow Surgical Procedures". This change is recommended based on the definitions of Blepharoplasty and Blepharoptosis repair. Blepharoplasty may be defined as plastic surgery of the eyelids which refers to a procedure that excises excessive skin and possibly muscle and fat from the upper lids and does not include ptosis repair. The intention of the LCD is relevant to all forms of plastic surgery on the eyelids including ptosis repair. Therefore, the society representative is recommending changing the title of the LCD to "Blepharoplasty, Blepharoptosis Repair and Brow Surgical Procedures".

Thank you for your comment. The title of the LCD will be changed to include "Blepharoptosis Repair".

5

First Coast received comment regarding the organization and formatting of the LCD. The commenter is requesting for the language in the LCD to be revised so that the criteria, requirements and documentation expected to be met supporting the medical and reasonable for coverage of blepharoplasty and brow surgical procedures are presented under the following subtopics: A. "Patient Signs and Symptoms," B. "Photographs," and C. "Visual Fields."

Thank you for your comment. The formatting of the criteria, requirements and documentation in the Billing and Coding Article will be revised as appropriate.

6

First Coast received a comment with recommendation to include clarifying language provided in the National Correct Coding Initiative (NCCI) effective October 1, 2017 regarding a coding for a medically necessary blepharoptosis procedure and cosmetic blepharoplasty procedure performed on an ipsilateral upper eyelid.

Thank you for your comment. The related Billing and Coding Article will be revised to include reference to the National Correct Coding Initiative (NCCI) Policy Manual for Medicare Services; Chapter 8 CPT codes 60000-69999, Section D. Ophthalmology.

7

Oklahoma Academy of Ophthalmology was noted without objections to the proposed LCD Blepharoplasty and Surgical Procedures of the Brow.

Thank you for your comment.

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Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
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