Local Coverage Article Response to Comments

Response to Comments: Bone Mass Measurement


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Response to Comments: Bone Mass Measurement
Article Type
Response to Comments
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The comment period for the Bone Mass Measurement DL39268 Local Coverage Determination (LCD) began on 3/31/22 and ended on 5/14/22. The notice period for L39268 begins on 8/4/22 and will become effective on 9/18/22.

The comment below was received from the provider community.

Response To Comments


I am writing on behalf of the International Society for Clinical Densitometry (ISCD) regarding the Proposed Local Coverage Determination (LCD) (DL39268) for Bone Mass Measurement (BMM), currently open for comment.

The ISCD is a multidisciplinary nonprofit organization devoted to promoting excellence in the assessment of skeletal densitometry through certification, education, facility accreditation, and development of official positions. Our official positions are designed to guide clinical practice through a rigorous review of scientific research. Our certification programs are designed to ensure competency in bone densitometry. The Society represents over 2,800 doctors, technologists, and other allied health providers in over 70 countries.

ISCD appreciates the time and effort the agency put into the LCD and is generally in favor of the recommendations with one significant change, namely with regards to indication number 6 of the proposed LCD: “Medicare may cover a bone mass measurement for a bene?ciary once every two years (if at least 23 months have passed since the month the last bone mass measurement was performed).”

Indication number 6 neglects to address an important and frequent scenario, the antiresorptive “holiday,” where repeat testing may be indicated prior to 23 months having elapsed. In such cases, patients who have undergone 3-5 years of antiresorptive therapy and are otherwise doing well begin a drug holiday. According to the proposed indication number 6, such a patient may not be able to receive imaging for up to two years. This signi?cantly delays the identi?cation of those patients who may need to resume therapy and limits the ability to con?rm the stability of bone density in those patients who do not. Therefore, the ISCD favors amending indication number 6 to allow for repeat testing after one year of a drug holiday. Thereafter, continued testing can be o?ered every two years until the resumption of therapy.

The ISCD agrees with the LCD as presently worded in all other respects. We appreciate your consideration of this suggested modification.

We appreciate your response and have carefully reviewed your concern. There was no literature submitted to support the increased testing frequency follow a drug holiday. If additional peer-reviewed published literature provides support for this indication, it can be re-evaluated through reconsideration.

Associated Documents

Related Local Coverage Documents
L39268 - Bone Mass Measurement
Related National Coverage Documents
Public Versions
Updated On Effective Dates Status
07/28/2022 08/04/2022 - N/A Currently in Effect You are here


  • Bone Mass Measurement