Medicare to Cover Lymphedema Compression Garments in 2024

Published in Lymphedema on July 18, 2023

Last week, VGM published an article summarizing a proposed rule published in the Federal Register on July 10, CMS-1780-P. That proposed rule covered multiple topics. One of the topics discussed within the proposed rule was the fact that, through the passage of the Lymphedema Treatment Act (LTA), Medicare will offer coverage for lymphedema-related compression garments beginning Jan. 1, 2024. Up to this point, the Medicare program has not offered coverage of compression garments for patients diagnosed with lymphedema. The proposed rule further outlines what that coverage may look like, and below are the main highlights of that new coverage: 

• Coverage for lymphedema-related products (compression garments, etc.) is slated to begin on Jan. 1, 2024 (Rx required with a diagnosis of lymphedema) 
• Coverage will be available for both standard and custom compression products 
• Language was added that could lead to the inclusion of lymphedema products in future iterations of the Competitive Bid Program (CBP) 
• Specifies that accreditation, quality standards, and enrollment criteria will be mandatory for all suppliers of compression therapy items 
• Fitting, training, and adjustment services will be included in the reimbursement rate for the product itself (though they did consider having a separate reimbursement rate for the initial fitting and are seeking additional comments around that) 
• Creation of some new/additional codes for several reasons (new codes for custom garments, certain compression products used for lymphedema can also be used as surgical dressing for venous stasis ulcers, and they would like separate coding to differentiate between the two applications, and possibly separate codes for daytime vs. nighttime garments, etc.) 
• Proposed reimbursement rates: The proposed rule contains a chart (around page 282 of 392) which outlines the reimbursement for the various compression garment HCPCS codes (methodology for custom garments not yet determined) 
• Proposed quantity limitations: two daytime garment sets, replaceable every six months; one nighttime garment set, replaceable on an annual basis (seeking comments around this specifically) 

You can view the entire proposed rule here. The instructions for comment submission can be found within the proposed rule as well, but below are the submission guidelines: 

• When commenting, please refer to file code CMS–1780–P.  
• Faxed comments will not be accepted. 
• Electronic comment submission (preferred method): You may submit electronic comments on this regulation to https://www.regulations.gov. Follow the instructions under the “submit a comment” tab. 
• Regular mail: You may mail written comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS–1780–P, P.O. Box 8013, Baltimore, MD 21244–8013.  
• Overnight mail: You may send written comments via express or overnight mail to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS–1780–P, Mail Stop C4–26–05, 7500 Security Boulevard, Baltimore, MD 21244–1850. 
• Please allow sufficient time for mailed comments to be received before the close of the comment period. The comment period will end at 5 p.m. ET on Aug. 29, 2023. 

With so much information being outlined in the proposed rule, and with topics such as reimbursement amounts, quantity limitations, creation of new HCPCS codes, potential inclusion in CMS’s Competitive Bidding Program, etc., rest assured that we at VGM are watching this topic very closely. We are excited that Medicare has recognized the need to offer coverage for these important products, but we also want to make sure that they are covered in a manner that allows providers like you to be able to offer the right products at the right time to each of your patients. We are also working with several other industry stakeholders to ensure that our comments are timely, concise, appropriate, and consistent for our industry. While we do plan to submit comments regarding this proposed rule ourselves, we encourage you to do so from the perspective of your business as well. If you have questions, concerns, or want to make sure certain topics are covered in the comments we submit, fill out this form. We will be communicating additional information and talking points regarding this proposed rule over the next few weeks, so stay tuned for that additional information.