The American College of Radiology® (ACR ®) joined 17 organizations in submitting a letter to the Centers for Medicare and Medicaid Services (CMS) Jan. 18, expressing concerns with revised processes the agency implemented to develop local coverage determination (LCD) policies. The letter asks CMS to consider several recommendations to ensure meaningful engagement of Contractor Advisory Committee (CAC) representatives in this process. For the past four years, the ACR CAC Network has monitored changes in the LCD process and will continue to seek further improvements.
The purpose of the CAC is to provide a formal mechanism for healthcare professionals to be informed of the evidence used in developing the LCD and promote communications between the Medicare Administrative Contractors (MACs)and the healthcare community. CAC members should serve in an advisory capacity as representatives of their constituency to review the quality of the evidence used in the development of an LCD. The organizations alleges MACs are failing to rely on CAC representatives to perform this function, resulting in CAC members effectively being cut out of the evidence review process.
Meaningful engagement by CAC representatives enables MACs to benefit from the education, experience and expertise of individuals who daily engage in patient care and can put evidence into context based on their practice area. Failure to uphold the advisory role of CAC members can result in reduced access to care, harm to Medicare beneficiaries and an unnecessary burden on healthcare practitioners.
If you have questions or would like more information about local coverage policies and activities, contact Alicia Blakey, ACR Senior Economic Policy Analyst.