LCD Reference Article Response To Comments Article

Response to Comments: Urine Drug Testing

A59496

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Contractor Information

Contractor Name	Contract Type	Contract Number	Jurisdiction	States
CGS Administrators, LLC	MAC - Part A	15101 - MAC A	J - 15	Kentucky
CGS Administrators, LLC	MAC - Part B	15102 - MAC B	J - 15	Kentucky
CGS Administrators, LLC	MAC - Part A	15201 - MAC A	J - 15	Ohio
CGS Administrators, LLC	MAC - Part B	15202 - MAC B	J - 15	Ohio

Article Information

General Information

Article ID
A59496

Article Title
Response to Comments: Urine Drug Testing

Article Type
Response to Comments

Original Effective Date
08/31/2023

Retirement Date
N/A

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Article Guidance

Article Text

Urine Drug Test LCD comment period was open 4/27/2023 and closed 6/10/2023. This Article is in response to submitted comments.

Response To Comments

Number	Comment	Response
1	“The American Clinical Laboratory Association (ACLA) would like to thank CGS for retiring the previous dLCD DL36029 posted on October 6, 2022. ACLA is pleased to see that the proposals where we had significant concerns were not included in the current dLCD. ACLA truly appreciates the opportunity to comment and engage with CGS during the LCD development process. We also commend CGS for developing a comprehensive overview of the various methodologies and indications for presumptive and definitive drug testing to ensure reasonable and necessary patient care. … ACLA would like to provide one comment on the Coverage Indications, Limitations, and/or Medical Necessity section and the discussion about the use of an Opioid Risk Tool. ACLA agrees that orders for urine drug testing should be based on specific patient information that supports an indication for testing. While we fully support a practitioner’s use of any of several evidence-based risk tools when prescribing/renewing a controlled substance, specific documentation requirements often lead to inefficiencies and difficulties in obtaining this information from the ordering practitioner. ACLA-member laboratories make significant efforts to educate ordering clinicians on coverage requirements and comply with records requests related to the adjudication of claims. However, laboratories often struggle to obtain medical documentation from health care practitioners to support the medical necessity of tests that they perform pursuant to the health care practitioners’ orders and for which the laboratories submit claims. The ordering health care provider creates and maintains the documentation about a patient encounter that supports the medical necessity of a test, yet the performing laboratory’s reimbursement is at stake when the documentation is not produced or is insufficient. Health care practitioners have no incentive to spend extra time and resources responding to requests from laboratories or from health plans for medical documentation. While ACLA does not recommend any specific changes to the language in the dLCD, we look forward to working with CGS, other Medicare Administrative Contractors, and the Centers For Medicare & Medicaid Services to find solutions to the ongoing difficulties in obtaining and transmitting appropriate medical documentation.”	Thank you for your comments. CGS understands ACLA’s concerns regarding the difficulty in obtaining the required documentation from the provider, when needed, and continues to be available to collaborate in finding Medicare compliant resolutions to this concern. However, for clinical laboratory tests to be covered by Medicare, the medical record must contain enough information about the patient's condition to support the medical necessity of the tests. While it is the laboratory's responsibility to obtain and submit medical documentation for the billed test(s) to CGS or other Medicare contractors when requested, they are often unable to provide this important documentation from the medical records because the information is with the ordering doctor’s office or practice. In these cases, for the laboratory to receive payment, they must request the information from the doctor ordering the test(s). Without the order or documentation such as progress notes indicating the intent to order the test(s), as well as supporting medical necessity, payment for the service(s) will be denied.
2	Millennium Health comments “ Millennium would like to thank CGS for retiring the prior dLCD DL36029, posted in 2022, and appreciates the opportunity to provide comment and participate in the LCD development process… Although the dLCD makes clear that ethanol is not a topic of discussion in the dLCD, the dLCD goes on to state as follows: “Ethanol is a known drug of abuse by is routinely tested in blood, not urine. In addition, the Drug Enforcement Administration (DEA) Resource Guide states that alcohol is exempt from control by the Controlled Substances Act (CSA).” While ethanol may be tested in blood, that should not limit the availability of testing for ethanol via urine. Testing for alcohol use via urine specimens is a necessary tool for clinicians monitoring patients in numerous settings and may be more accessible and useful than blood testing, especially for those being treated and monitored in a clinical setting for an alcohol addiction or disorder. Blood alcohol testing can be useful when levels of acute use are needed, but this method has limitations that do not align with clinical settings where abstinence is being monitored. Aside from being an invasive test requiring a blood draw (something many clinical offices do not have skilled staff to perform), the detection windows for use are much lower for ethanol in blood (~6-12 hours window of detection) than in urine (~80 hours window of detection when monitoring urine levels of alcohol metabolites). So, as an example, patients can avoid detection when monitored via blood testing by simply avoiding alcohol the prior evening, whereas urine testing gives a more accurate indication of alcohol use. Given the above stated clinical advantages of monitoring for alcohol use in urine vs. blood, we believe that access to this testing in urine, when deemed medically necessary by a treating clinician, is important and should be considered in any future policymaking.”	This dLCD clearly states that ethanol is not a topic of discussion in this dLCD. Therefore, there is no restriction for billing ethanol by whatever means tested and payment will be based on criteria of Reasonable and Necessary, benefit category, etc.

Coding Information

CPT/HCPCS Codes

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Group 1

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N/A

Group 1 Codes

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ICD-10-CM Codes that Support Medical Necessity

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Group 1

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N/A

Group 1 Codes

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ICD-10-CM Codes that DO NOT Support Medical Necessity

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N/A

Group 1 Codes

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ICD-10-PCS Codes

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Group 1

Group 1 Paragraph

N/A

Group 1 Codes

N/A

Additional ICD-10 Information

Bill Type Codes

Code	Description

Revenue Codes

Code	Description

Coding Table Information

Excluded CPT/HCPCS Codes - Table Format

Code	Descriptor Generic Name	Descriptor Brand Name	Exclusion Effective Date	Exclusion End Date	Reason for Exclusion
			N/A	N/A

Non-Excluded CPT/HCPCS Ended Codes - Table Format

Code	Descriptor Generic Name	Descriptor Brand Name	Exclusion Effective Date	Exclusion End Date	Reason for Exclusion

Revision History Information

N/A

Associated Documents

Related Local Coverage Documents
LCDs
L36029 - Urine Drug Testing

Updated On	Effective Dates	Status
08/24/2023	08/31/2023 - N/A	Currently in Effect	You are here

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Response to Comments: Urine Drug Testing

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Group 1

CPT/HCPCS Modifiers

Group 1

ICD-10-CM Codes that Support Medical Necessity

Group 1

ICD-10-CM Codes that DO NOT Support Medical Necessity

Group 1

ICD-10-PCS Codes

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Group 1

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