LCD Reference Article Response To Comments Article

Response to Comments: Hyaluronic Acid Injections for Knee Osteoarthritis

A59137

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Source Article ID
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Article ID
A59137
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Article Title
Response to Comments: Hyaluronic Acid Injections for Knee Osteoarthritis
Article Type
Response to Comments
Original Effective Date
07/07/2022
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The comment period for the Hyaluronic Acid Injections for Knee Osteoarthritis DL39260 Local Coverage Determination (LCD) began on 3/31/22 and ended on 5/14/22. The notice period for L39260 begins on 7/7/22 and will become effective on 8/21/22. The comment below was received from the provider community.

Response To Comments

Number Comment Response
1

I’ve been a physician for 35 years and I currently own 14 medical practices in 8 States overseen by 4 Medicare Administrative Contractors. All my medical practices do business as Arthritis Knee Pain Centers.

All the medical practices I own focus on treating the pain caused by osteoarthritis of the knee. The CDC recently released a study showing a 30% increase in deaths caused by opioid addiction last year in America. At Arthritis Knee Pain Centers, we treat chronic knee pain caused by osteoarthritis without opioids or surgery. In fact, there are no prescription pads in any of my medical practices.

My medical practices inject FDA-approved Viscosupplement gels into the intraarticular space of the knee, thus cushioning the joint, decreasing the patients’ pain, and increasing their mobility. To ensure the best chance for the procedure to work, my practices inject the Viscosupplement gels with fluoroscopic confirmation of placement. This is similar to what Medicare considers best practice for SI, or sacroiliac joint, injections. The medical literature is clear in its published findings, even experienced physicians miss the intraarticular knee joint space up to 40% of the time without the use of fluoroscopy. Avalere Health performed a study that showed Medicare would save $1.3 B/year if every physician-administered these injections under fluoroscopy, increasing the procedure’s success rate and decreasing the need for total knee replacement surgery. This study is cited in the white paper I wrote about Viscsupplementation (provided for review).

There was a published actuarial study in 2015 by Young in Orthopedics This Week. BC/BS stopped paying for viscosupplementation injections. The following year, knee replacements increased by 498%!

Medicare should revise its LCDs to require fluoroscopic confirmation of placement and make it easier for patients to qualify for this medically necessary treatment.

Reference was provided for review.

Thank you for your comments. We have taken into consideration and reviewed your comments on requiring fluoroscopic confirmation of placement of Viscosupplement injections. The proposed Hyaluronic Acid Injections for Knee Osteoarthritis LCD states under Coverage Indications, Limitations and/or Medical Necessity subheading Limitations “#8. Imaging procedures for the purpose of needle guidance that may be considered reasonable and necessary are ultrasound or fluoroscopy. The documentation must support why imaging is needed for needle guidance and insertion.” We do concur that fluoroscopy is considered reasonable and necessary, however, request documentation to support fluoroscopic imaging.

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Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
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