Retirement of Pneumatic Compression Devices (PCD) Local Coverage Determination (LCD) and Related Policy Article

Effective November 14, 2024

The Medicare DME MACs jointly announced the Retirement of Pneumatic Compression Devices (PCD) Local Coverage Determination (LCD) and Related Policy Article – Effective November 14, 2024. With the retirement of the LCD and Policy Article, providers and suppliers should refer to the CMS  National Coverage Determination (NCD) – Pneumatic Compression Devices (280.6) which addresses coverage criteria for the devices. In addition, providers and suppliers should review the recently published joint DME MAC correct coding article titled “Pneumatic Compression Devices – Correct Coding and Billing” for more information regarding the coverage and billing of pneumatic compression devices.

The PCD policy has been facing increasing scrutiny with high volume of audits from various contractors and the intriguing case Michael Greenwald brought against the United States Department of Health and Human Services Secretary, Xavier Becerra with case “Greenwald v. Becerra”. The litigation ruling did not directly force or compel the retirement of the LCD and related policy article. The DME MACs ultimately decided that the NCD is sufficiently detailed at this time, and there is no longer a need for the more prescriptive LCD.

Suppliers should take the time to orient themselves with the NCD as it contains the coverage requirements they will be held-to for dates of services on or after November 14, 2024. Suppliers might be relieved or surprised to learn that the NCD is not as restrictive as the LCD. However, I’d caution suppliers not to deviate too far from the engrained principles of the LCD without first thoroughly reviewing the requirements of the NCD. The NCD does have some ambiguity that the LCD attempted to clarify. For example, the LCD reads, “A segmented, calibrated gradient PCD (E0652) is only covered when the individual has unique characteristics which prevent them from receiving adequate satisfactory pneumatic compression treatment using a nonsegmented device along with a segmented appliance or compression device without manual control of the pressure in each chamber.

A PCD coded as E0652, is covered for the treatment of lymphedema extending onto the chest, trunk and/or abdomen when all of the following are met:

• The beneficiary has lymphedema of an extremity as defined above
• The coverage criteria for an E0650 or E0651 are met
• The beneficiary has lymphedema extending onto the chest, trunk and/or abdomen that extends past the limits of a standard compression sleeve, and the chest, trunk and/or abdominal lymphedema has failed to improve with a four-week trial.”

Contrary to the LCD, for the E062, the NCD only state “the only time that a segmented, calibrated gradient pneumatic compression device (HCPCs code E0652) would be covered is when the individual has unique characteristics that prevent them from receiving satisfactory pneumatic compression treatment using a nonsegmented device in conjunction with a segmented appliance or a segmented compression device without manual control of pressure in each chamber.” While both LCD and NCD mentioned the documented need of unique characteristics, the NCD stops short of mandating the trial of an E0650 or E0651. While unique characteristics are not defined, the patient’s medical records must clearly document or paint the picture of the said unique characteristics that warrants the need for the E0652. I would also encourage documentation and consideration of conservative therapies. If a more conservative therapy was considered but not trialed, the records should reflect why said therapy was ruled out.

Suppliers are encouraged to establish standard operating procedures that will ensure the supplier’s documentation shows substantial compliance with the published NCD. At the time of this article, the CERT, RAC and MACs are currently auditing PCDs. Suppliers should also be vigilant in ensuring auditing contractors are not applying the LCD requirements for dates of service on or after November 14, 2024.

The DME MACs will timely provide additional education. If you have questions in the interim, please do not hesitate to reach out to Noel Neil at [email protected].