Novitas has posted the long-awaited finalized LCD and Article for "Surgical Treatment of Nails" effective 1/30/2022.

In summary, as your MPMA CAC representative, I provided in writing numerous recommendations as did I engage the APMA Health Policy and Practice and suggested changes to the policy several months ago (during the draft process).

Additionally, via the Webex CAC Open Meeting for Novitas, I provided verbal testimony about the numerous concerns in the proposed policy. Supportive arguments were provided to justify changes prior to the finalized version. Article - Response to Comments: Surgical Treatment of Nails (A58961) (cms.gov)

The updated policy is not effective until January 30, 2022 f or those that utilize these CPT codes 11730, 11732,11750, and 11765.

All MPMA members should review the LCD and LCA (Billing Article) to better understand the changes.

The most significant change addresses the frequency of performing these procedures. Be aware of an "8-month" period where you can't bill the same T Code (TA-T9).

However, the carrier states that under certain circumstances, exceptions may be considered.

This is from the LCA "For a medically necessary repeat nail excision on the same finger or toe, use modifier 76 (repeat procedure or service by the same physician or other qualified health care professional) or modifier 77 (repeat procedure by another physician or other qualified health care professional). The medical record documentation must be specific to the indication, such as ingrown nail of the opposite border or new significant pathology on the same border recently treated. Compliance with the use of modifier 76 and modifier 77 may be monitored and addressed through post payment data analysis and subsequent medical review audits."

It is my understanding that APMA will provide additional information since a similar policy is applicable for First Coast (another major Medicare carrier).

The plan is to review this on the next MPMA membership Zoom in January.

The future LCD link is here: LCD - Surgical Treatment of Nails (L34887) (cms.gov)

The future LCA link is here: Article - Billing and Coding: Surgical Treatment of Nails (A52998) (cms.gov)