Local Coverage Article Response to Comments

Response to Comments: DL37800 Allergen Immunotherapy

A56118

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Article ID
A56118
Article Title
Response to Comments: DL37800 Allergen Immunotherapy
Article Type
Response to Comments
Original Effective Date
10/18/2018
Retirement Date
N/A
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The MAC JN Contractor received comments for the proposed LCD DL37800 Allergen Immunotherapy for the comment period May 17, 2018 through July 5, 2018.  Below is a summary of the comments received and the contractor's response.

Response To Comments

NumberCommentResponse
1

One commenter asked if the Draft LCD DL37800 should also include positive coverage for Sublingual Immunotherapy Treatments (SLIT).

Local coverage determinations (LCDs) specify under what clinical circumstances an item or service is considered to be reasonable and necessary (R&N). LCDs are administrative and educational tools to assist providers in submitting correct claims for payment. Medicare Administrative Contractors (MACs) publish LCDs to provide guidance to the public and medical community within their jurisdictions. MACs develop LCDs by considering medical literature, the advice of local medical societies and medical consultants, public comments, and comments from the provider community. MACs have authority over LCD criteria but do not have jurisdiction over National Coverage Determinations (NCDs). Please see the NCD for Antigens Prepared for Sublingual Administration (110.9).

2

One commenter asked if the Draft LCD DL37800 should include in the preparation portion of the LCD that the physicians “supervise” the process rather than implying that the physician has to be the one to make the serum.

Thank you for your comment. Local coverage determinations (LCDs) specify under what clinical circumstances an item or service is considered to be reasonable and necessary (R&N). LCDs are administrative and educational tools to assist providers in submitting correct claims for payment. Medicare Administrative Contractors (MACs) publish LCDs to provide guidance to the public and medical community within their jurisdictions. MACs develop LCDs by considering medical literature, the advice of local medical societies and medical consultants, public comments, and comments from the provider community. MACs have authority over LCD criteria but do not have jurisdiction over Internet Only Manuals (IOMs). Please see IOM Medicare Benefit Policy Manual, Publication 100-02, Chapter 15, section 50.4.4.1 Payment for Antigens.

3

One commenter asked if the Draft LCD DL37800 should include in the prescribing physician’s section of the LCD, language stating “outside of the fields of ENT and Allergy, a provider must demonstrate adequate training and experience in Allergan immunotherapy”.

Thank you for your comment. There may be providers outside the fields of ENT and Allergy that meet the expectation of a Qualified Provider as outlined in this LCD. First Coast will make no changes to the LCD.

4

One commenter asked if First Coast will clarify the Draft LCD DL37800 in the place of service section of the LCD with at home treatments to also include Sublingual Immunotherapy Treatments (SLIT).

Thank you for your comment. Please see response #1 Sublingual Immunotherapy Treatments (SLIT) is not covered by CMS per the NCD 110.9.

5

One commenter asked if the Draft LCD DL37800 should include the adjustment of dosages “based on protocol” as opposed to every time trying out and specifying or documenting build up and maintenance doses and immunotherapy schedules thus requiring unnecessary physician visits.

Thank you for your comment. The LCD does not preclude the use of a standardized, medical society accepted protocol for determining the individual patient’s build-up phase dose, the maintenance dose, and the immunotherapy schedule. Clinical judgment is required to determine whether a conventional or accelerated schedule will be used in the build-up phase, when altering the dose from the initial plan of treatment, or when altering the schedule of administration from the initial plan of treatment. First Coast will make no changes to the LCD.

6

Comment was received from the Florida Allergy Society and they were in agreement with the language in the LCD that discussed proper qualifications for healthcare professionals giving immunotherapy.

Thank you for your comment.

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Updated On Effective Dates Status
08/24/2018 10/18/2018 - N/A Currently in Effect You are here

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