First Coast Service Options/Novitas Solutions patch testing unit of service reduction averted
In 2021, two Medicare Administrative Contractors (MACs), First Coast Service Options (FCSO) and Novitas Solutions, published proposed Local Coverage Determinations (LCDs) with recommendations to reduce the skin patch testing units for allergic and other contact dermatitis from 80 to 65 units. In a combined effort, the American Academy of Dermatology Association’s Dermatologic Contractor Advisory Committee (DermCAC)* and Health Care Finance Committee (HCFC)** joined forces to protect dermatologists’ ability to provide quality and patient access to care.
In response to the proposed patch testing LCD policy changes, the DermCAC coalition and the HCFC submitted comment letters to both FCSO and Novitas indicating the dermatology perspective and clinical experience underscoring that it is more appropriate to forgo limited and standard screening of patients and proceed directly to comprehensive patch testing for many patients to correctly evaluate their dermatitis, especially in circumstances where patch testing is necessary due to the patient’s occupational setting.
Patch testing remains the gold standard and objective scientific method available to physicians to diagnose allergic contact dermatitis (ACD). Improving the accuracy of diagnosing ACD is increased through appropriate and comprehensive use of patch testing to lessen both the morbidity and economic impact caused by this chronic skin disorder. In contrast to the limited and screening series patch test, comprehensive patch testing encompasses a broader range of available allergens, allowing for greater diagnostic potential and improved patient outcomes.
As a result of the combined efforts of the AADA’s DermCAC and HCFC, FCSO and Novitas Solutions relented on their respective proposed LCDs; both carriers will allow 80 units of skin patch testing for ACD. This victory for dermatologists and their patients means that Medicare beneficiaries will have access to an expanded panel of tests to efficiently diagnose and treat this chronic debilitating disease that can significantly affect a patient’s quality of life.
Although both the FCSO and Novitas LCDs (L33261 and L36241 respectively) recognize that patch testing is the gold standard in identifying the cause of allergic contact dermatitis, some policy limitations must be adhered to when dermatologists provide and report this service. The LCDs have specific limitations related to the justification of medical necessity as well as the number of and frequency of performing the patch test.
Policy limitations
According to the LCDs, “allergy patch testing is considered medically reasonable and necessary when used to diagnose a patient’s allergic contact dermatitis with clear clinical suspicion of the chemical related to the allergy. Testing should be limited to those chemicals relevant to the problem which may include for example, dermatitis due to detergents, oils and greases, solvents, drugs and medicines in contact with skin, other chemical products, food in contact with skin, plants (except food), cosmetics, and metals, such as nickel and rubber additives.” Further, the number of allergy tests performed should be judicious and dependent upon the patient’s history, age, environment, and living conditions (e.g., region of the country), occupation, and activities as well as physical findings and provider’s clinical judgment as documented in the medical record.
The LCDs also state that “all patients should not necessarily receive the same tests or the same number of sensitivity tests.” It however states that because ACD “is frequently caused by unsuspected substances, up to 80 patch tests may be required for diagnosis.” Nevertheless, regular use of a significant number of skin tests or routine annual tests without a distinct clinical indication are clearly not suggested.
Claim appeal resources
For services rendered within Jurisdictions JN and JH (FCSO and Novitas) respectively, for which the number of patch test units are inappropriately reduced by the MAC, the AAD has developed a template letter that can be customized to assist dermatologists in their claim appeal efforts. The AAD’s Private Payer Resource Center appeal letter tool includes several template letters, including for patch testing, to help dermatologist appeal efforts to private payers when claim adjudication results in a denial or improper reduction of reimbursement.
* The DermCAC is the national coalition of dermatologist representatives and alternates who have been selected by their state dermatology society to represent dermatologists in that state by attending quarterly meetings with their Carrier Medical Director to discuss Medicare coding issues and payment policy. To ensure that Medicare patients are not harmed or denied access to dermatologic care, AADA staff works with DermCAC members to carefully review and assess the nature and scope of either the new policy or proposed changes to existing policies.
** The Health Care Finance Committee, composed of 13 member representatives, monitors, advises, advocates, and acts on payment policy issues that impact dermatologic services provided by AADA members. These issues may involve payment guidelines and valuations, reporting initiatives that affect reimbursement, code editing software systems and claims processing. When necessary, this committee will advocate for fair treatment of AADA members and their patients through appropriate interaction with and education of concerned parties.
