Modernization of LCD process and relocation of codes

Feb. 1, 2019 / By Divya Verma, RHIA

On October 3rd, 2018 Medicare announced significant changes to the Local Coverage Determination (LCD) process. As a result, a major change to the LCD format was also announced in Change Request 10901:

“MACs shall remove all codes from LCDs and place them in billing & coding articles that are linked to the LCD. CMS will provide additional instructions on the date upon which this change will be effective.”

Procedure and diagnoses codes have existed in LCDs since they originated in 2003 and were also in Local Medical Review Policies (LMRPs) before they were converted to LCDs. Medicare Coverage database (MCD) currently holds 10,483 active LCDs and 15,063 active articles for all regions (as of January 8, 2019), so this might impact stakeholders in a big way. Medicare Administrative Contractors (MACs) who maintain these LCDs and articles have a huge task ahead of them to relocate all procedure and diagnoses codes from LCDs to their associated articles, in addition to more tasks related to the new LCD process. Both LCDs and articles will be revised—LCDs to remove codes and articles to add codes.

The next and most significant groups affected are the providers, healthcare professionals and suppliers who depend on these LCDs to check if a service or item is covered for Medicare beneficiaries. They should familiarize themselves with the new LCD format (and the whole new LCD process) and learn how to locate these articles in MCDs.

Health information technology vendors also have a big task ahead in keeping LCD edits and links up to date for their clients as MACs start updating their LCDs and articles.

There is currently no deadline to complete this requirement, but we are starting to see a few revised LCDs reflecting the change. For example, LCDs Category III CPT® Codes (L33392) and Molecular Pathology Procedures (L35000) are revised effective January 1, 2019 and no longer have coding guidance listed. Providers should now refer to articles associated with these LCDs.   

LCDs and articles are revised for many reasons throughout a given year (which I described briefly in this blog), and here is yet another reason to add this year! Healthcare providers and their appropriate staff should be familiar with Medicare coverage before providing services or items to Medicare beneficiaries.

[NOTE: Links and data in this blog are as of January 8, 2019 from the Medicare Coverage Database and are subject to change.]

Divya Verma, is a compliance analyst for the Medical Necessity and Compliance division within 3M Health Information Systems.


  1. CMS Accelerates Innovation and Promotes Patient Access to Medical Technology
  2. Summary of Significant Changes to the Medicare Program Integrity Manual Chapter 13 – Local Coverage Determinations
  3. Transmittal 829- SUBJECT: Local Coverage Determinations (LCDs)
  4. Local Coverage Determinations
  5. LCD status report
  6. Article status report
  7. Medicare Coverage database (MCD)
  8. Category III CPT® Codes (L33392)
  9. Molecular Pathology Procedures (L35000)

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