Local Coverage Determination (LCD)

Mohs Micrographic Surgery

L35704

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Proposed LCD
Proposed LCDs are works in progress that are available on the Medicare Coverage Database site for public review. Proposed LCDs are not necessarily a reflection of the current policies or practices of the contractor.

Document Note

Note History

Contractor Information

LCD Information

Document Information

Source LCD ID
N/A
LCD ID
L35704
Original ICD-9 LCD ID
Not Applicable
LCD Title
Mohs Micrographic Surgery
Proposed LCD in Comment Period
N/A
Source Proposed LCD
N/A
Original Effective Date
For services performed on or after 10/01/2015
Revision Effective Date
For services performed on or after 12/01/2019
Revision Ending Date
N/A
Retirement Date
N/A
Notice Period Start Date
N/A
Notice Period End Date
N/A

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Fee schedules, relative value units, conversion factors and/or related components are not assigned by the AMA, are not part of CPT, and the AMA is not recommending their use. The AMA does not directly or indirectly practice medicine or dispense medical services. The AMA assumes no liability for data contained or not contained herein.

Current Dental Terminology © 2023 American Dental Association. All rights reserved.

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Issue

Issue Description
Issue - Explanation of Change Between Proposed LCD and Final LCD

CMS National Coverage Policy

Title XVIII of the Social Security Act, Section 1862(a)(1)(A). This section allows coverage and payment for only those services that are considered to be medically reasonable and necessary.

Title XVIII of the Social Security Act, Section 1833(e). This section prohibits Medicare payment for any claim which lacks the necessary information to process the claim.

CMS Publications:

CMS Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 30, Physician Services
CMS Publication 100-02, Medicare Benefit Policy Manual, Chapter 16, Section 120, Cosmetic Surgery
CMS Publication 100-04, Medicare Claims Processing Manual, Chapter 12 Section 40-40.6, Surgeons and Global Surgery
CMS Publication 100-04, Medicare Claims Processing Manual, Chapter 12, Section 60, Payment for Pathology Services
CMS Transmittal No. 434, Publication 100-04, Medicare Claims Processing Manual, Change Request #3458, January 14, 2005, Addition of CLIA Edits to Certain Health Care Procedure Coding System (HCPCS) Codes for Mohs Surgery.

Coverage Guidance

Coverage Indications, Limitations, and/or Medical Necessity

Coverage Indications, Limitations, and/or Medical Necessity

As defined by the American Medical Association Current Procedural Terminology (American Medical
Association, Chicago, IL), Mohs Micrographic Surgery (MMS) is a technique for the removal of complex or ill-defined skin cancer with histologic examination of 100% of the surgical margins. It is a combination of surgical excision and surgical pathology that requires a single physician to act in 2 integrated but separate and distinct capacities: surgeon and pathologist. If either of these responsibilities is delegated to another physician who reports the services separately, these codes should not be reported. The Mohs surgeon removes the tumor tissue and maps and divides the tumor specimen into pieces, and each piece is embedded into an individual tissue block for histopathologic (hematoxylin-eosin or toluidine blue) examination. Thus, a tissue block in MMS is defined as an individual tissue piece embedded in a mounting medium for sectioning. (American Medical Association. Mohs Micrographic Surgery. CPT Assistant 2006;16:1-7)

Mohs micrographic surgery is a two-step process: the tumor is removed in stages, followed by immediate histologic evaluation of the margins of the specimen(s). Further excision is performed until all margins are clear. The physician performing MMS furnishes both the surgical and pathological services, i.e., the excision and the histologic evaluation of the specimen(s).

Mohs surgery is usually an outpatient procedure done under local anesthesia (with or without sedation).

The majority of simple skin cancers can be managed by simple excision or destruction techniques. The medical records should clearly document that Mohs surgery was chosen because of the complexity (e.g. poorly defined clinical borders, possible deep invasion, prior irradiation), size or location (e.g. maximum conservation of tumor-free tissue is important).

Indications:
After careful review Medicare Jurisdictions E and F have adopted coverage for Mohs Micrographic Surgery in accordance with the 2012 Appropriate Use Criteria (AUC) for Mohs Micrographic Surgery as published in the Journal of the American Academy of Dermatology Volume 67, Issue 4, pp 531-550, October 2012. These criteria were compiled based on collaboration of the American Academy of Dermatology, the American College of Mohs Surgery, the American Society of Dermatologic Surgery Association and the American Society for Mohs surgery based on evidence based medicine, clinical practice experience and expert judgment.

Clinical settings that are supported by the criteria as denoted by the CPT® codes and ICD-10-CM codes listed in the Billing and Coding Article will be considered for coverage when properly performed and the indications, procedure and findings/results clearly and legibly documented within the beneficiary’s clinical record. Clinical settings noted to be inappropriate by the criteria and not otherwise covered in this LCD will be denied and should NOT be billed to Medicare as MMS.

The majority of simple skin cancers can be managed by simple excision or destruction techniques. The medical records should clearly show that MMS was chosen because of the complexity (e.g. poorly defined clinical borders, possible deep invasion, prior irradiation), size or location (e.g. maximum conservation of tumor-free tissue is important).

Definitions:

1. Area H: Mask areas of the face (central face, eyelids [including inner/outer canthi], eyebrows, nose, lips [cutaneous/mucosal/vermillion], chin, ear and periauricular skin/sulci, temple), genitalia (including perineal and perianal areas), hands, feet, nail units, ankles, nipples/areola

2. Area M: Cheeks, forehead, scalp, neck, jawline, pretibial surface.

3. Area L: Trunk and extremities (excluding pretibial surfaces, hands, feet, nail units and ankles).

4. Immunocompromised:
a. patient with HIV/AIDS, organ transplant, hematologic malignancy or pharmacologic suppression.

5. Genetic Syndromes: basal cell nevus syndrome, xeroderma pigmentosa, or other syndromes at high risk for skin cancer.

6. Healthy: no immunosuppression, no prior radiation therapy to affected area, no chronic infections and no genetic syndromes that predispose to skin cancer.

7. Prior Radiated Skin: patient has previously received therapeutic radiation in this area of the body.

8. Aggressive features:

      a. For Basal Cell Carcinoma
      i. Morpheaform, fibrosing, sclerosing
      ii. Infiltrating
      iii. Perineural
      iv. Metatypical/keratotic
      v. Micronodular
      b. For Squamous Cell Carcinoma
      i. Sclerosing
      ii. Basosquamous excluding keratotic BCC
      iii. Small cell
      iv. Poorly or undifferentiated, i.e. high degree of polymorphism, high mitotic rate and/or low degree of keratinization
      v. Perineural or perivascular
      vi. Spindle cell
      vii. Pagetoid
      viii. Infiltrating
      ix. Keratoacanthoma (KA) type: central facial
      x. Single Cell
      xi. Clear Cell
      xii. Lymphoepithelial
      xiii. Sarcomatoid
      xiv. Breslow depth below 2mm or greater
      xv. Clark level IV or greater

9. Tissue Block:

A block is the plate that tissue is placed upon, coated with embedding medium, frozen, and then placed into the microtome for cutting. Thus, a block is a plate with tissue and mounting medium on it. How many tissue pieces go onto the plate (block) does not matter. The technician, with possible input from the physician, decides how many tissue pieces from a given excision stage would fit on one tissue plate (block). For example, a specimen may be butterflied and put on one block (tissue plate), or the same specimen could be bisected and both tissue pieces put on one plate (block). It is still one block.

Another example: one may take a subsequent Mohs excision stage as three separate, non-contiguous pieces (specimens). Each of the tissue pieces is considered as a separate tissue specimen; however, depending upon their size and the technician's proficiency, all three pieces could be placed upon one plate (one block), or two pieces on one plate and one on another plate (2 blocks), or each of the three tissue pieces (specimens) could be placed on individual plates (3 blocks).

The block is the billing unit, not the tissue piece.

Indications:

Medicare will consider reimbursement for MMS for the following indications and anatomic locations:

I. Basal Cell Carcinoma
A. Recurrent BCC of any size or unexpected positive margin on recent excision (healthy or immunocompromised or genetic syndrome(s))

i. Aggressive Pathology

1. Area H, M, and/or L

ii. Nodular pathology

1. Area H, M, and/or L

iii. Superficial pathology

1. Area H and M only

2. No coverage for Area L

B. Primary Aggressive

i. Size ≤ 0.5 cm

1. Area H and M.

2. Area L may be covered on redetermination

ii. Size ≥ 0.6 cm

1. Area H, M, and L

 

C. Primary Nodular BCC (Healthy patient)

i. Size ≤ 0.5 – 1 cm

1. Area H and M only

2. No coverage for Area L

ii. Size 1.1 – 2 cm

1. Area H and M.

2. Area L may be covered on redetermination

iii. Size ≥ 2

1. Area H, M, and L

 

D. Primary Nodular BCC (Immunocompromised patient)

i. Size ≤ 0.5 cm

1. Area H and M only

2. No coverage for Area L.

ii. Size 0.6 – 1 cm

1. Area H and M.

2. Area L may be covered on redetermination

iii. Size ≥ 2 cm

1. Area H, M, and L

 

E. Primary Superficial BCC (Healthy Patient)

i. Size ≤ 0.5 cm

1. Area H.

2. Area M may be considered for coverage on redetermination.

3. No coverage for Area L.

ii. Size ≥ 0.6 cm

1. Area H and M.

2. No coverage for Area L.

 

F. Primary Superficial BCC (Immunocompromised Patient)

i. Size ≤ 1.0 cm

1. Area H and M.

2. No coverage for Area L.

ii. Size > 1.0 cm

1. Area H and M.

2. Area L may be covered on redetermination

 

II. Squamous Cell Carcinoma

A. Recurrent SCC of any size or unexpected positive margin on recent excision

i. Aggressive Pathology

1. Area H, M, and L

ii. Verrucous Pathology

1. Area H

iii. KA-type SCC (Not central facial)

1. Area H, M, and L

iv. In situ/Bowen

1. Area H and M.

2. Area L may be covered on redetermination

v. AK with focal SCC in situ; Bowenoid AK; SCC in situ, AK type

1. NOT Covered

vi. Without aggressive histologic features, < 2 mm depth without other defining features, Clark level ≤ III

1. Area H, M, and L

 

B. Primary aggressive SCC (healthy patients)

i. Size – all

1. Area H, M, and L

 

C. Primary aggressive SCC (Immunocompromised Patients)

i. Size – all

1. Area H, M, and L

 

D. Primary SCC Without aggressive histologic features, < 2 mm depth without other defining features, Clark level ≤ III (healthy patients)

i. Size ≤ 1.0 cm

1. Area H and M.

2. No coverage for Area L

ii. Size 1.1 – 2 cm

1. Area H and M.

2. Area L may be covered on redetermination

iii. Size > 2 cm

1. Area H, M, and L

 

E. Primary SCC Without aggressive histologic features, < 2 mm depth without other defining features, Clark level ≤ III (Immunocompromised patients)

i. Size ≤ 1.0 cm

1. Area H and M.

2. Area L may be covered on redetermination

ii. Size ≥ 1.1 cm

1. Area H, M, and L

 

F. Primary verrucous SCC (healthy or immunocompromised patients)

i. All Sizes

1. Area H only

2. No Coverage for areas M and L as such tumors in these areas are extremely rare. The rare occurrence may be covered on redetermination.

 

G. Primary SCC KA type, not central facial (healthy patients)

i. Size ≤ 1.0 cm

1. Area H and M.

2. No coverage for Area L

ii. Size ≥ 1.1 cm

1. Area H, M, and L

 

H. Primary SCC KA type, not central facial (Immunocompromised patients)

i. Size ≤ 0.5 cm

1. Area H and M. Area L may be covered on redetermination

ii. Size ≥ 0.6 cm

1. Area H, M, and L.

 

I. Primary in situ SCC/Bowen disease (healthy patients)

i. Size ≤ 1.0 cm

1. Area H and M.

2. No coverage for Area L

ii. Size 1.1 – 2 cm

1. Area H and M.

2. Area L may be covered on redetermination

iii. Size > 2 cm

1. Area H, M, and L

 

J. Primary in situ SCC/Bowen disease (Immunocompromised patients)

i. Size ≤ 0.5 cm

1. Area H and M.

2. No coverage for Area L

ii. Size 0.6 – 1 cm

1. Area H and M.

2. Area L may be covered on redetermination

iii. Size ≥ 1.1 cm

1. Area H, M, and L

 

K. Primary AK with focal SCC in situ; Bowenoid AK; SCC in situ, AK type (healthy or immunocompromised patients)

i. Any size

1. Not covered

 

III. Basal or Squamous Cell Carcinoma

A. Primary BCC or SCC regardless of sub-type, size or depth arising in:

i. Prior irradiated skin;

ii. Traumatic scar;

iii. Area of Osteomyelitis;

iv. Area of chronic inflammation/ulceration, or

v. Patients with genetic syndromes predisposing to skin cancer

1. Area H, M, and L

 

IV. Lentigo Maligna and melanoma in situ
A. Primary lentigo maligna (healthy or immunocompromised patients)

1. Area H and M.

2. Area L may be covered on redetermination

B. Locally recurrent lentigo maligna (healthy or immunocompromised patients)

1. Area H, M, and L

C. Primary melanoma in situ; non-lentigo maligna (healthy or immunocompromised patients)

1. Area H and M.

2. Area L may be covered on redetermination

D. Locally recurrent melanoma in situ; non-lentigo maligna (healthy or immunocompromised patients)

1. Area H, M, and L

 

V. Other less common skin cancers

A. Adenocystic carcinoma

1. Area H, M, and L

B. Adnexal carcinoma

1. Area H, M, and L

C. Apocrine/eccrine carcinoma

1. Area H, M, and L

D. Angiosarcoma

1. Area H, M, and L subject to records review for medical necessity.

E. Atypical fibroxanthoma

1. Area H, M, and L

F. Bowenoid papulosis

1. Not covered

G. Dermatofibrosarcoma protuberans

1. Area H, M, and L

H. Desmoplastic trichoepithelioma

1. Area H and M subject to medical records review for medical necessity.

2. Area L not covered

I. Extramammary Paget Disease

1. Area H, M, and L

J. Leiomyosarcoma

1. Area H, M, and L

K. Malignant fibrous histiocytoma

1. Area H, M, and L

L. Merkel Cell Carcinoma

1. Area H and M.

2. Area L may be covered on redetermination

M. Microcystic Adnexal Carcinoma

1. Area H, M, and L

N. Mucinous Carcinoma

1. Area H, M, and L

O. Sebaceous Carcinoma

1. Area H, M, and L

P. Rare Biopsy proven malignancies not otherwise specified

1. Area H, M, and L will be looked at for medical necessity on a pre-pay basis or may be covered on redetermination.


Limitations:

Only physicians (MD/DO) may perform Mohs micrographic surgery. (See Sections 1861 [s] [2] and 1862 [a] [140 of Title XVIII of the Social Security Act; 42 CFR, Sections 410.74, 410.75, 410.76 and 419.22; 58 FR 18543, April 7, 2000.)

The physician (MD/DO) performing Mohs micrographic surgery must be specifically trained and highly skilled in MMS techniques and pathologic identification.

 

Summary of Evidence

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Analysis of Evidence (Rationale for Determination)

N/A

Proposed Process Information

Synopsis of Changes
Changes Fields Changed
N/A
Associated Information
Sources of Information
Bibliography
Open Meetings
Meeting Date Meeting States Meeting Information
N/A
Contractor Advisory Committee (CAC) Meetings
Meeting Date Meeting States Meeting Information
N/A
MAC Meeting Information URLs
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Proposed LCD Posting Date
Comment Period Start Date
Comment Period End Date
Reason for Proposed LCD
Requestor Information
This request was MAC initiated.
Requestor Name Requestor Letter
View Letter
N/A
Contact for Comments on Proposed LCD

Coding Information

Bill Type Codes

Code Description

Please accept the License to see the codes.

N/A

Revenue Codes

Code Description

Please accept the License to see the codes.

N/A

CPT/HCPCS Codes

Please accept the License to see the codes.

N/A

ICD-10-CM Codes that Support Medical Necessity

Group 1

Group 1 Paragraph:

N/A

Group 1 Codes:

N/A

N/A

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

Group 1

Group 1 Paragraph:

N/A

Group 1 Codes:

N/A

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Additional ICD-10 Information

General Information

Associated Information

N/A

Sources of Information
1. Journal of American Academy of Dermatology, Volume 67, Issue 4 , Pages 531-550, October 2012

Bibliography

N/A

Revision History Information

Revision History Date Revision History Number Revision History Explanation Reasons for Change
12/01/2019 R7

The LCD is revised to remove CPT/HCPCS codes in the Keyword Section of the LCD.

At this time 21st Century Cures Act will apply to new and revised LCDs that restrict coverage which requires comment and notice. This revision is not a restriction to the coverage determination; and, therefore not all the fields included on the LCD are applicable as noted in this policy.

  • Other (The LCD is revised to remove CPT/HCPCS codes in the Keyword Section of the LCD.
    )
12/01/2019 R6

12/01/2019: At this time 21st Century Cures Act will apply to new and revised LCDs that restrict coverage which requires comment and notice. This revision is not a restriction to the coverage.

As required by CR 10901, all billing and coding information has been moved to the companion article, this article is linked to the LCD.

  • Provider Education/Guidance
  • Revisions Due To Code Removal
10/01/2018 R5

09/06/2018 - At this time 21st Century Cures Act will apply to new and revised LCDs that restrict coverage which requires comment and notice. This revision is not a restriction to the coverage determination; and, therefore not all the fields included on the LCD are applicable as noted in this policy.

05/06/19 Approved to link the LCD to Billing and Coding of for Pathology Services on the Same Date of Service (DOS) as Mohs Surgery article A56515

  • Other (Other (Approved to be able to link LCD to Billing and Coding of for Pathology Services on the Same Date of Service (DOS) as Mohs Surgery article A56515.))
10/01/2018 R4

09/06/2018 - At this time 21st Century Cures Act will apply to new and revised LCDs that restrict coverage which requires comment and notice. This revision is not a restriction to the coverage determination; and, therefore not all the fields included on the LCD are applicable as noted in this policy.

 

The following ICD-110 codes were added and deleted per the Annual ICD-10 Updates.

Added: C43.111, C43.112, C43.121, C43.122, C4A.111, C4A.112, C4A.121, C4A.122, C44.1121, C44.1122, C44.1191, C44.1192, C44.1221, C44.1222, C44.1291, C44.1292, C44.1921, C44.1922, C44.1991, C44.1992, D03.111, D03.112, D03.121, D03.122, D04.111, D4.112, D04.121 and D04.122.

Deleted: C43.11, C43.12, C4A.11, C4A.12, C44.112, C44.119, C44.122, C44.129, C44.192, C44.199, D03.11, D03.12, D04.11 and D04.12.

  • Revisions Due To ICD-10-CM Code Changes
10/01/2015 R3 LCD revised to add C43.21 and C43.22 effective 10/01/2015.
  • Other (Provider Outreach and Education question from a provider)
10/01/2015 R2 This final LCD, effective 10/1/2015, combines JFA L35703 into the JFB LCD L35704 so that both JFA and JFB contract numbers will have the same final MCD LCD number.
  • Creation of Uniform LCDs Within a MAC Jurisdiction
10/01/2015 R1 R1 LCD revised to add ICD-10 codes D03.21-D03.22 effective 10/1/15
  • Creation of Uniform LCDs Within a MAC Jurisdiction
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Associated Documents

Attachments
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Related Local Coverage Documents
Articles
A56515 - Billing and Coding: Mohs Micrographic Surgery
Related National Coverage Documents
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Public Versions
Updated On Effective Dates Status
01/29/2020 12/01/2019 - N/A Currently in Effect You are here
11/07/2019 12/01/2019 - N/A Superseded View
Some older versions have been archived. Please visit the MCD Archive Site to retrieve them.

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