New L-Codes and Allowables for 2002

As many readers know, Medicare codes change every year. This year there were a number of modifications to existing L-Codes including a number of new codes, primarily for various microprocessor-controlled features that have been clinically available for years. It is encouraging to see the L-Codes updated to reflect more contemporary care, as this keeps the L-Coding System from becoming outmoded.

You can download a list of all the 2002 L-Codes and associated Allowables [d02Jan_a.ZIP] from the Medicare web site at www.hcfa.gov/stats/pufiles.htm.

The biggest surprise this year was the deletion of code L-5669 covering roll-on silicone liners. AOPA, NAAOP, and other industry associations have all strongly protested this bizarre decision, and many have written letters requesting reconsideration.

Hopefully, after some additional pondering, Medicare will reverse this mistake so that patients will not be denied access to such well-accepted rehabilitation techniques for very long. The text of the letter I sent expressing my concerns is reprinted below:

Centers for Medicare and Medicare Services
C5-08-27
7500 Security Blvd
Baltimore, MD 21244-1850

Saturday, December 01, 2001

Dear Ms. Riley:

I am writing to add my voice to those imploring you, Dr. Nelson, and Dr. Oleck to do whatever you can to reverse the pending deletion of code L5669. As I'm sure other clinical experts have advised, this will disrupt care for a significant number of amputees since there is no plausible alternative for coding this commonplace service except to use L5999. Some patients may try reverting to the older type of liners covered by the L5660, 62, & 64 codes, but these services have been decreasing in utilization for many years for good reason: they have not proven to be as effective or as reliable as the newer and better-engineered roll-on liners.

Frankly, my major concern with the deletion of L5669 is with the loss of credibility that CMS will suffer once this is implemented as well as the long-term lack of confidence in the L-Coding system that will result. To the experienced clinician, deleting L5669 makes no logical sense and seems arbitrary and capricious. To the many manufacturers worldwide who have invested years of private research funding into the tiny niche of amputee rehabilitation, this sends the chilling message that CMS will abruptly and unilaterally roll back the level of routinely covered care by omitting existing codes for contemporary treatment options without any rationale. To the beneficiaries who are amputees, and to the clinicians providing their care, this sends the message that Medicare coverage is a fleeting thing: widely accepted services that were covered in 2001 can disappear with no warning in the New Year.

I am deeply concerned that the unintended consequences of this single Code deletion will be so negative and so pervasive that it will literally take years for the CMS to rebuild its credibility in the eyes of the beneficiaries and rehabilitation specialists involved in amputee care. This is a threat to the integrity of the program commensurate with the backlash that resulted from an ill-advised Policy change proposal in an earlier decade that would have precluded the provision of modern prosthetic knee, ankle, and foot components.

The prosthetic Policy debacle set an encouraging example: implementation was delayed and the proposal was modified after consultation with subject matter experts. The final Policy that was implemented has proven to be very effective as a result. I hope for similar success in resolving this issue.

I urge you, Dr. Nelson, and Dr. Oleck to do everything in your power to stop the deletion of L5669. It will be very difficult to undo the damage that will result once this ill-advised change to the L-Coding system has been implemented.



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