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Back to Serum Iron Studies NCD 190.18 (Addition of ICD-9-CM diagnosis code 285.22 Anemia of Malignancy and 285.29 Anemia of Other Chronic Condition)

Coding Analysis for Labs (CAL) View Public Comments

Serum Iron Studies NCD 190.18 (Addition of ICD-9-CM diagnosis code 285.22 Anemia of Malignancy and 285.29 Anemia of Other Chronic Condition)

CAG-00406N

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Total Comments: 2

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Bocchino, Carmella	Title: EVP, Clinical Affairs & Strategic Planning Organization: America's Health Insurance Plans (AHIP) Date: 12/04/2008 Comment: December 5, 2008 Jeffrey Roche, MD Medical Officer Centers for Medicare and Medicaid Services Mail Stop C1-11-25 7500 Security Boulevard Baltimore, Maryland 21244-1850 Dear Dr. Roche: Thank you for the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s) proposed Coverage Analysis for Laboratories (CALs) Tracking Sheet for Serum Iron Studies NCD 190.18 (Addition of ICD-9-CM diagnosis code 285.22 Anemia of Malignancy and 285.29 Anemia of Other Chronic Condition) (CAG-00406N). America’s Health Insurance Plans (AHIP) is the national association representing nearly 1,300 health insurance plans providing coverage to more than 200 million Americans. We are pleased to submit these comments on behalf of our members. General Comments AHIP encourages CMS to ensure that all patients receive the most effective and appropriate treatments as supported by sufficient levels of clinical evidence. Therefore, we support the addition of the two proposed ICD-9-CM diagnosis codes (285.22 Anemia of Malignancy and 285.29 Anemia of Other Chronic Condition) to the Serum Iron Studies national coverage determination (NCD) 190.18. The inclusion of code 285.22 Anemia of Malignancy would correspond with Section 1a under Indications and Limitations of Coverage, within the Serum Iron Studies NCD, which states that serum iron tests are indicated for “malignant, chronic inflammatory and infectious conditions associated with anemia which may be present in a similar manner to iron deficient anemia.” Also within the current NCD, codes are presently covered for many other varied malignancies, such as malignant neoplasms of bone (170.0-176.9), digestive (150.0-159.9) and respiratory organs (160.0-165.9), and other carcinomas. The inclusion of 285.29 Anemia of Other Chronic Condition would be consistent with Section 1a (as described above) and Section 4 of the Indications and Limitations of Coverage section which states that “Serum ferritin may be appropriate for monitoring iron status in patients with chronic renal disease with or without dialysis.” Additionally, within the current NCD there are already several codes for other chronic conditions such as chronic liver disease and cirrhosis (571.0-571.9), chronic kidney disease (585.4 – 585.9), and heart failure (428.0-428.9). Thank you for the opportunity to provide comments on this issue. Sincerely, Carmella Bocchino Executive Vice President, Clinical Affairs & Strategic Planning Less December 5, 2008 Jeffrey Roche, MD Medical Officer Centers for Medicare and Medicaid Services Mail Stop C1-11-25 7500 Security Boulevard Baltimore, Maryland 21244-1850 Dear Dr. Roche: Thank you for the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s) proposed Coverage Analysis for Laboratories (CALs) Tracking Sheet for Serum Iron Studies NCD 190.18 (Addition of ICD-9-CM diagnosis code More
Kaushansky, MD, Kenneth	Title: President Organization: American Society of Hematology (ASH) Date: 12/04/2008 Comment: December 5, 2008 Lisa Eggleston Lead Analyst - NCD 190.18 Centers for Medicare and Medicaid Services Dear Ms. Eggleston, The American Society of Hematology (ASH) appreciates the opportunity to submit comments on the addition of ICD-9-CM codes to NCD 190.18 – Serum Iron Studies. ASH represents over 11,000 hematologists in the United States who are committed to the treatment of blood and blood-related diseases. ASH members include hematologists and hematologist/oncologists who regularly render services to Medicare beneficiaries. ASH supports CMS’ decision to add ICD-9-CM codes 285.22 – Anemia of Malignancy and 285.29 – Anemia of Other Chronic Conditions as ICD-9-CM diagnosis codes covered under the National Coverage Determination on Serum Iron Studies. Serum iron studies are important in the evaluation of anemia. Serum iron may be altered in patients with anemia due to malignancy as well as other chronic conditions. It is important that these patients have access to this diagnostic tool. ASH would be happy to provide CMS with any additional information on this issue. Please contact Carol Schwartz, Senior Manager of Policy and Practice at (202)292-0258 or cschwartz@hematology.org. Sincerely, Kenneth Kaushansky, MD President Less December 5, 2008 Lisa Eggleston Lead Analyst - NCD 190.18 Centers for Medicare and Medicaid Services Dear Ms. Eggleston, The American Society of Hematology (ASH) appreciates the opportunity to submit comments on the addition of ICD-9-CM codes to NCD 190.18 – Serum Iron Studies. ASH represents over 11,000 hematologists in the United States who are committed to the treatment of blood and blood-related diseases. ASH members include hematologists and More

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