LCD Reference Article Response To Comments Article

Response to Comments: Heavy Metal Testing

A58628

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Article ID
A58628
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Article Title
Response to Comments: Heavy Metal Testing
Article Type
Response to Comments
Original Effective Date
04/15/2021
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As an important part of Medicare Local Coverage Determination (LCD) development, National Government Services solicits comments from the provider community and from members of the public who may be affected by or interested in our LCDs. The purpose of the advice and comment process is to gain the expertise and experience of those commenting.

We would like to thank those who suggested changes to the LCD for Heavy Metal Testing. The official notice period for the final LCD begins on February 25, 2021 and the final determination will become effective for services rendered on or after April 15, 2021.

Response To Comments

Number Comment Response
1

We received the following comment from a QIO:

I think it is very important NOT to use urine testing to diagnose heavy metal poisoning. There are multiple provider using provoked urine tests to justify chelation therapy - and almost anyone with a provoked urine test will end up with a positive urine screen. That is why toxicologists ONLY recommend blood testing for the use of screening for heavy metal toxicity. The QIO has been doing focused reviews and sanction panel actions against multiple holistic, alternative, and natural medicine providers who justify multiple chelation treatments at great cost and pretty much not indicated by any scientific studies – for treating provoked urine measurements of any of a large list of metal toxins. This unscientific and unwarranted therapy certainly can be done - but Medicare should no be in the business of paying for tests that are not useful. An unprovoked urine test may act as a screen to do a blood test for heavy metals – but that is the only test that any reputable science supports for treatment of heavy metals with chelation.

We agree that there are a number of providers who practice holistic, alternative, natural medicine, and/or other unproven methods of medicine. Their services are not standard and should not be paid. These practitioners are ubiquitous and not confined only to NGS localities. They however use several laboratories that specialize in these treatments. We also agree that provoking excretion of heavy metals by being “primed” with chelation agents and related methods gets spurious “documentation” in urine of heavy metal toxicity. This policy was created because of abuse in a Midwestern laboratory specializing is urine drug testing: their lawyers and CEO met with us and said, “There is no LMRP stating our testing is wrong.” Thus this policy was created. A number of heavy metals (e.g. chromium) are only payable per our LCD as serum testing. Similarly, boron, phosphorous, silica, strontium, sulfur, uranium, and vanadium testings are specifically excluded: these tests had been often ordered and performed. Of note, one practitioner ordered uranium testing whenever a patient had prostate cancer. As our LCD notes, “However, before any testing for heavy metal is ordered, a detailed medical history of the patient must be obtained, including a careful documentation of occupational and avocational exposure to these toxins. A complete physical examination must be done.” Without this documentation, we would deny on review any such claims.

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Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
Related Local Coverage Documents
LCDs
L35074 - Heavy Metal Testing
Related National Coverage Documents
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Updated On Effective Dates Status
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