Local Coverage Article Response to Comments

Response to Comments: Thoracic Aortography and Carotid, Vertebral, and Subclavian Angiography

A55817

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Article ID
A55817
Article Title
Response to Comments: Thoracic Aortography and Carotid, Vertebral, and Subclavian Angiography
Article Type
Response to Comments
Original Effective Date
12/07/2017
Retirement Date
N/A
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The following are the comment summaries and contractor responses for Novitas Solutions Draft Local Coverage Determination (LCD) DL35035 Thoracic Aortography and Carotid, Vertebral, and Subclavian Angiography which was posted for comment on May 18, 2017 and presented at the June 2017 Contractor Advisory Committee (CAC) Meeting. All comments were reviewed and incorporated into the final LCD where applicable.

Response To Comments

NumberCommentResponse
1

Comment #1
A comment was received stating that the draft LCD indications are appropriately inclusive as are the technical requirements. The commenter had a question pertaining to the bilateral use of the procedure codes.

Thank you for your comment and support of the LCD. All of the CPT codes included in the draft LCD may be reported with the bilateral modifier or twice on the same day by any other means (e.g. with LT and RT modifiers, or with a ‘2’ in the units field).  This allows bilateral studies when indicated.

2

Comment #2
A commenter expressed concern about using the “appeals” process for providers to request “reconsideration” of the many deleted but valid indications. No literature was submitted for review.

Thank you for your comment. The appeals process (also known as redetermination process) is done on a claim by claim basis whereby medical record documentation is reviewed for medical necessity of the service(s) rendered. The redetermination process may be utilized for consideration of services performed outside of the reasonable and necessary requirements in this LCD.

The LCD reconsideration process is a different process and it is posted on the Novitas website for providers. After finalization, the LCD reconsideration process may be utilized for consideration of additional requests for specific diagnoses with submission of supporting literature.

3

Comment #3
A comment was received stating that the proposed title of the LCD “Thoracic Aortography and Carotid, Vertebral, and Subclavian Angiography” is not reflective of the anatomic regions included in the policy content. It is noted that craniocerebral angiography codes are covered indications but not in the title. The policy title also excludes arteriovenous fistula, traumatic shoulder injury and related anatomy, but this commenter agrees with the covered indications.

Novitas agrees that additional anatomical areas could be added to the title of this LCD, however, the draft is a revision of a LCD that has been in effect since 2012.  At this time, no change in the name is warranted. Thank you for the comment.

4

Comment #4
A comment was received that the draft LCD excludes important indications that are in the current LCD L35035, such as atherosclerosis of autologous coronary artery bypass grafts, atherosclerosis of native arteries of extremities, and vein bypass grafts of extremities. The commenter submitted a list of diagnosis codes in the current LCD for review, and it appears that the ICD-10 codes being requested with this comment are I25.720-I25.798.  There was no literature submitted for review. The commenter also questions if some of the lower extremity indications are included in another policy.


Thank you for your comment. The lower extremity diagnoses have been removed from this draft policy because they would be best addressed in the Diagnostic Aortography and Renal Angiography policy (LCD L35092).

The range of diagnostic codes in the existing LCD includes diagnoses for atherosclerotic heart disease with native coronary artery without angina pectoris, atherosclerosis of autologous and other artery coronary artery bypass grafts with unstable angina, with unstable angina with documented spasm, and with other forms of angina pectoris, with unstable angina pectoris. These diagnoses were omitted from the draft LCD as these clinical conditions would be appropriately billed in the cardiac catheterization range (CPT code 93452 + range). The diagnosis codes I25.720 - I25.798 will not be added to the final policy. The redetermination process may be utilized for consideration of services performed outside of the reasonable and necessary requirements in this LCD. After finalization, the LCD reconsideration process may be utilized for consideration of additional requests for specific diagnoses with submission of supporting literature.

5

Comment #5
A comment was received requesting coverage of diagnoses code T82.595 (A, D, and S) “Other mechanical complication of umbrella device, initial (A), subsequent encounter (D), and sequela (S)” for the assessment and treatment of defective “umbrella devices”. The commenter stated that this code presumably includes inferior vena cava filters (IVC filters) and carotid filtering devices which are widely used to capture distal emboli.

The comment is appreciated. After review, Novitas agrees that ICD-10-CM code T82.595A/D/S as well as T82.515A/D/S should be added to the final policy to allow for carotid vessel umbrella devices.  Other similar diagnostic codes already in the draft include: T82.525A/D/S, T82.321A/D/S, and T82.391A/D/S.

6

Comment #6
A comment was received with the submission of a list of all diagnoses in the draft LCD compared to the existing LCD diagnoses list and asks to reestablish them in the draft.
 

Thank you for your comment. With the implementation of ICD-10 coding, it is expected that providers code the diagnosis to the highest level of specificity. The medical record must support the use of the selected ICD-10-CM code(s). Any unspecified laterality code in which a RT, LT and bilateral diagnosis code is available will not be reinstated in the final LCD. Some diagnosis codes that were not included are for those that have a higher level of specificity code available within the range or instances where another more appropriate specific diagnosis code was available for use. Those diagnoses not reinstated include the following code requests:

C69.00
C69.10
C69.20 
C69.30
C69.40
C69.50
C69.60
C69.80
C69.90
C70.9
C72.40
D42.9
G81.00
G81.10
H34.00
H34.10
H34.219
H34.239
H34.8190
H34.8191
H34.829
H34.8390
H34.8391
H35.079
H49.00
H49.10
H49.20
H49.30
H49.40
H49.889
H53.469
I60.10
I60.30
I63.019
I63.139
I63.219
I63.239
I63.319
I63.329
I63.339
I63.349
I63.419
I63.429
I63.439
I63.449
I63.50
I63.519
I63.529
I63.539
I63.549
I65.09
I65.29
I66.09
I66.19
I66.29
S06.9X0A-S06.9X6S
S15.009A-S15.009S
S15.019A-S15.019S
S15.029A-S15.029S
S15.109A-S15.109S
S15.119A-S15.119S
S15.129A-S15.129S
S15.199A-S15.199S
S15.209A-S15.209S
S15.219A-S15.219S
S15.229A-S15.229S
S15.299A-S15.299S
S15.309A-S15.309S
S15.319A-S15.319S
S15.329A-S15.329S
S25.109A-S25.109S
S25.119A-S25.119S
S25.129A-S25.129S
S48.019A-S48.019S
S48.119A-S49.119S
S48.129A-S48.129S
S49.919A-S48.919S
T82.318A-T82.319S
T82.321A-T82.321S
T82.328A-T82.329S
T82.338A –T82.339S
T82.398A-T82.399S

Lower extremity diagnosis code ranges would not be appropriate for inclusion as they do not meet the scope of this LCD. Please refer to LCD L35092 Diagnostic Abdominal Aortography and Renal Angiography when applicable. Therefore, the following diagnoses will not be added:

I70.211-I70.599
T82.320A-T82.320S
T82.322A-T82.322S
T82.330A-T82.330S
T82.332A-T82.332S
T82.390A-T82.390D
T82.392A-T82.392S

The following codes were submitted to be reviewed again, but were found to already be included the Draft LCD:

C72.31-C72.32
C79.49
G81.01-G81.04
I60.52
I63.112
S06.1X9S
S06.366S
S06.5X6S
S06.5X9A-S06.5X9D
S06.6X9A-S06.6X9D
S06.820S-S06.822D
S15.101S-S15.102D
S25.01XA-S25.01XS
S25.191A
S48.011D-S48.011S
S48.112A-S48.112S

The following diagnosis codes have a descriptor including ‘death’. If these codes are reported, they would require a redetermination to review the medical necessity of a study being needed following a diagnosis of death.  Hence, the submitted code ranges related to this issue that will not be reinstated to the LCD include:

S06.1X7A-S06.1X8S
S06.2X7A-S06.2X8S
S06.307A-S06.308S
S06.347A-S06.348S
S06.357A-S06.358S
S06.367A-S06.368S
S06.4X7A-S06.4X7S
S06.5X7A-S06.5X8S
S06.6X7A-S06.6X8S
S06.827A- S06.828S
S06.897A-S06.898S
S06.9X7A-S06.9X8S

Hemodialysis catheter procedures are not included in the scope of this policy. Therefore, diagnosis codes specific to dialysis catheter are not appropriate to include. Data analysis revealed that the provider type of nephrology was reporting a large portion of these codes.  By removing the generic first, second, and third order vascular access procedure codes, the LCD will now have a limited focus on very specific CPT codes. The following diagnosis codes will not be added to the LCD:

T82.41X-T82.49XS

However, Novitas will follow these codes carefully through the appeals process and in the edit effectiveness process to assure inappropriate denials would not occur.  A large number of diagnoses were included in the draft for surgically created arteriovenous shunts as well.

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