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Trailblazer Issues First LCD on Pulmonary Rehabilitation

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November 3, 2010

Trailblazer, the Medicare Part A/B Administrative Contractor for Jurisdiction 4, which includes the states of Colorado, New Mexico, Oklahoma and Texas has finalized a local coverage determination (LCD) on pulmonary rehabilitation.

This is the first local policy since the national benefit went into effect January 1, 2010. The LCD is effective December 14, 2010.

During the comment period on the proposed policies, AACVPR, AARC, ATS and NAMDRC submitted joint comments on several issues. Two of the noteworthy ones involved Trailblazer’s proposed definition of “immediately available” with respect to the direct supervision requirements and the imposition of an 18-month separation between the inital 36 sessions and the subsequent 36 sessions based on medical need.

In the final rule, Trailblazer eliminated the 18-month restriction. It did not, however, remove the definition of “immediately available.” The final policy requires the supervising physician to be able to “respond to an emergency in less than one minute.” In our joint comments, we stressed that the Centers for Medicare and Medicare Services has not defined “immediately available” in timeframes such as minutes or seconds and recommended the definition be deleted. The contractor has the discretion, however, to set a limit as it deems appropriate.

Pulmonary function tests meeting the definition of COPD GOLD Classifications II, III and IV are required within 3 months of the initiation of PR. The patient must also have a diagnosis of either emphysema or chronic bronchitis. The final policy permits limited licensed practitioners (e.g., nurse practitioners, physician assistants) to write a PR order in addition to the physician.

At this time, we are uncertain if other Medicare A/B contractors will follow the example set by Trailblazer and issue LCDs within their respective jurisdictions.