October 12, 2020
Widespread Post-Pay Service Specific Review Announcement – HCPCS Codes L1902; L1906; L1971; L4396; L4397
CGS's Medical Review staff will be conducting a complex post-pay service-specific medical review of HCPCS Codes L1902; L1906; L1971; L4396; L4397 (Ankle-Foot Orthosis). This review will be conducted because data analysis revealed that Jurisdiction B's allowed dollars for HCPCS Codes L1902; L1906; L1971; L4396; and L4397 were significantly above expected amounts. Additionally, the Orthotics policy group ranked #1 in total CERT errors.
CGS would like to remind suppliers of the importance of responding to Additional Documentation Request (ADR) letters. Authorization for the collection of this information is included in Federal Law at SSA 1833 (e) and in Federal regulation at 42 CFR 424.5(a)(6). Suppliers are in violation of Supplier Standard #28 when, upon request, they fail to provide requested documentation to a Medicare contractor. Therefore, the consequences of failure to provide records may not only be a claim denial but also referral to the National Supplier Clearinghouse (NSC).
The ADR letter will contain the following information:
- Treating practitioner's written order;
- Relevant medical records to verify the claim for the lower extremity orthosis meets all statutory and reasonable and necessary criteria as defined in the Ankle-Foot/Knee-Ankle-Foot Orthoses Local Coverage Determination and related Policy Article.
- Copies of supplier's records for dates of direct patient contact related to the evaluation, fitting, and delivery of the orthosis;
- Manufacturer's name, model name and number of the item(s) provided;
- If the beneficiary has same or similar items, documentation indicating the reason new equipment/item(s) is reasonable and necessary;
- Any other pertinent documentation; and
- Copy of Advance Beneficiary Notice (ABN) if one was obtained