During the 45-day comment period, which ended on 02/10/2020, the DME MACs received a total of sixty-five comments. Similar comments were grouped together, resulting in twenty-three unique comments and responses.
Introduction to Responses
The DME MACs appreciate the comments received from stakeholders during the open comment period on the proposed Oxygen and Oxygen Equipment Local Coverage Determination (DL33797).
Pursuant to the CMS Program Integrity Manual (CMS Pub. 100-08) Chapter 13, §§13.2.3 and 13.5.3:
Acceptance by individual health care providers, or even a limited group of health care providers, does not indicate general acceptance of the item or service by the medical community.
In conducting a review, MACs shall use the available evidence of general acceptance by the medical community, such as published original research in peer-reviewed medical journals, systematic reviews and meta-analyses, evidence-based consensus statements and clinical guidelines.
Accordingly, the final policy and our response to comments are based on the best currently available published clinical evidence, to support optimal health outcomes in Medicare beneficiaries with chronic wounds.