The AVLS is currently working on an advocacy effort to oppose the propsed LCD by Novitas regarding treatment of varicose veins. The AVLS is dealing with the issue from several angles, including: a coalition with other societies and industry, public comment, letters to members of Congress, and community/patient engagement. Below, you will find links to resources, sample letters and background for members in the affected area, who wish to participate.
Novitas, Inc., a Medicare Administrative Contractor (MAC), recently proposed a draft Local Coverage Determination (LCD) regarding Treatment of Varicose Veins of the Lower Extremities (DL34924). This LCD would affect the twelve states within Centers for Medicare and Medicaid Services (CMS) jurisdiction J-H, which includes: Arkansas, Colorado, Delaware, District of Columbia, Louisiana, Maryland, Mississippi, New Jersey, New Mexico, Oklahoma, Pennsylvania and Texas.
The AVLS is taking an active role in formally objecting to the proposed policy to ensure that the changes do not limit patients’ access to care. To that end, the AVLS provided expert testimony at the January 26, 2017 Novitas open public meeting, and we are currently participating with a coalition of several societies and organizations opposed to the draft policy. In addition to the official efforts undertaken by the AVLS, we are asking our members in the impacted jurisdictions to submit their own written comments directly to Novitas. The public comment period ends on March 9, 2017, so time is of the essence.
Links to the full text of the draft policy, supplementary reading materials, options to submit comments, and recommended references can be found at the end of this email. In order to maintain a consistent message and cover all of our concerns, the AVLS has put together a list of specific objections that can be included in your comments. Novitas will reject public comments that look like a form letter, so please draft your comments into your own voice as much as possible.
It is important that coverage policies are made based on clinical evidence and established science, not claims data. If you live in the Novitas jurisdiction, please make your voice heard. If adopted, policies such as this will have far-reaching consequences for patient care, not just in the states specified, but for the whole country.
Below are links to the full text of the draft policy and the link to submit comments. If you have any questions or concerns, please email us at [email protected] .
To access the full proposed/draft LCD, CLICK HERE.
For additional information regarding draft policy status and history, CLICK HERE.
Comments can be submitted via one of the four (4) methods listed below (all methods are given equal consideration). If you are referencing literature for the Novitas Contractor Medical Directors to consider with your comments, the full text article(s) (PDF) must be submitted via the postal service or e-mail.
Electronically at: SUBMIT COMMENTS ONLINE
Email: [email protected]
US Mail addressed to:
Medical Policy Department
Union Trust Building
501 Grant Street
Pittsburgh, PA 15219
Fax: (717) 728-8767
Recommended References for Citation in Public Comments:
The letter below is a sample letter physicians in the affected jurisdiction can send to their member of Congress. The letter is a suggestion and can be changed to reflect the voice of the sender. In addition, the chart below provides contact information for those members of Congress who represent the impacted areas.
|Dr. Michael Burgess
The AVLS is also urging clinicians to get their patients involved in the process. This can be a powerful way for the patient’s voice to be heard. Below are links to credible message boards where those conversations are taking place. Please encourage your patients to post to these with their success stories.