VGM & ASSOCIATESHealthcare MSO
Full Menu Search

A Summary of the Final Rule of the Lymphedema Treatment Act Recently Released by CMS

Published in Government Relations on November 05, 2023

CMS has released their final rule regarding the implementation of the Lymphedema Treatment Act, which outlines how they intend to begin covering compression garments and related accessories for patients diagnosed with lymphedema. The full 65-page document can be viewed here. (beginning on page 350). Below is a summary of some of the key provisions of the final rule:

Covered items: The following items will be covered by Medicare beginning January 1, 2024 for patients diagnosed with lymphedema:

  • both standard and custom fitted gradient compression garments
  • gradient compression wraps with adjustable straps
  • compression bandaging systems
  • other items determined to be lymphedema compression treatment items

Frequency limitations: Medicare will cover:

  • 3 (three) daytime garments or wraps with adjustable straps for each affected limb or area of the body, replaced every 6 months.
  • 2 (two) nighttime garments for each affected limb or area of the body, replaced once every 2 years.
    • *These limitations are higher than what was originally suggested in the proposed rule, and industry stakeholder comments played a key role in raising the frequency limitations that were finalized.

HCPCS Codes: There are a couple tables contained within the final rule, namely tables FF-A 1 and FF-A 2, which outline the codes that will be used to represent many of the compression related products used to treat patients with lymphedema.

  • CMS is keeping several of the existing compression codes that several of you may already be familiar with (A6530-A6549 range). These are outlined in Table FF-A 1 on page 372.
  • CMS is creating 57 new HCPCS codes to better represent additional lymphedema related compression products. These new HCPCS codes have yet to be determined, but the descriptions of each new code can be found in Table FF-A 2 on page 389.
  • CMS is creating 9 additional new A-codes to replace 9 existing S-codes (S8420-S8428) that currently represent compression sleeves, gloves, gauntlets, wraps, and bandages.

Pricing/Reimbursement: CMS has not yet finalized the full fee schedule for all of the compression codes. They have, however, provided some example pricing for some codes in table FF-A 3 (page 398). They also stated that “Final payment amounts will be determined in accordance with the methodology as previously detailed based on the most recent data available in late 2023 and will most likely be higher than these example payment amounts.” They also stated that they will use available pricing data from Medicaid, VHA, TRICARE, and internet retailers in establishing allowables for these items.


VGM will continue to monitor the information that is released regarding this topic, and will provide you with additional updates as appropriate. Please don’t hesitate to reach out to our Government and Regulatory team at 800-642-6065 if you have additional questions.

Get Connected

Stay up-to-date on the latest resources and news provided by VGM & Associates.

Sign Up for Email

From Our Experts

Proposed Rule Suggests Significant Change To Accreditation Process thumbnail Proposed Rule Suggests Significant Change To Accreditation Process The recently released proposed rule CMS-1828-P contains a significant change that could reshape how suppliers navigate accreditation. The rule proposes a major change that would require suppliers to be surveyed and reaccredited annually instead of the current three (3) year cadence. This proposal raises substantial questions about both operational feasibility and cost implications. August Of Action: Your Chance To Connect With Congress thumbnail August Of Action: Your Chance To Connect With Congress It's time to take advantage of August Of Action—a perfect opportunity to make your voice heard. Every summer, federal legislators return to their home states during the Congressional recess. While it gives them a break from Washington D.C., it's primarily a time for them to connect with constituents like you. HR1 Passes House, Advances to President Trump's Desk for Signature thumbnail HR1 Passes House, Advances to President Trump's Desk for Signature After extensive negotiations and partisan debate, the House has officially passed HR1, clearing the path for the bill to be signed into law by President Donald Trump. The legislation, which aims to reduce federal healthcare expenditures, contains several provisions that may impact the durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS) industry. CMS files the Proposed Rule that sheds light on the next round of the Competitive Bidding Program thumbnail CMS files the Proposed Rule that sheds light on the next round of the Competitive Bidding Program On June 30, 2025, CMS filed the anticipated Proposed Rule that includes updates to the Competitive Bidding Program (CBP). Public comments are due 60 days from June 30, 2025. Below is a high-level summary of the rule. It is critical to note that, according to the Proposed Rule Fact Sheet dated June 30, 2025, CMS has stated that they have not announced the specific product categories they are bidding or the specific timeframe for the next competition. Those specifics will be forthcoming in a fu Senate Narrowly Passes HR1, Sending It Back to House for Final Approval thumbnail Senate Narrowly Passes HR1, Sending It Back to House for Final Approval President Donald Trump's sweeping legislative package, formally titled the One Big, Beautiful Bill Act, now referred to as HR1., cleared the Senate today in a dramatic 51–50 vote, with Vice President JD Vance casting the tie-breaking vote. The bill now returns to the House, where lawmakers must decide whether to adopt the Senate's revised version or negotiate further changes before it can reach the president's desk. Several Prominent Medicaid Provisions in Senate's Budget Bill Deemed in Violation of Byrd Rule thumbnail Several Prominent Medicaid Provisions in Senate's Budget Bill Deemed in Violation of Byrd Rule Senate Parliamentarian Elizabeth MacDonough advised this week that multiple Medicaid provisions in the Senate's reconciliation bill would violate Senate procedure by violating the Byrd Rule. The Byrd Rule is a Senate-specific procedural process that allows Senators to prevent or block inclusion of extraneous provisions in reconciliation bills. Other provisions are still under review. Evaluating the Value of a Payer Contract thumbnail Evaluating the Value of a Payer Contract In our last article, Key Payers Denied Your Application Citing Their Network Is Closed – Now What?, we discussed strategies for addressing payer contracting denials due to a closed network. As indicated, this process can be an extremely time-consuming exercise with no guarantees and mixed results. Below are a few things to consider as you evaluate whether a contract is worth the extra effort. Webinar: Webinar: "Navigating The New CMS Landscape: RADs, HMVs, and Supplier Survival" on June 25 at 1 p.m. CT. The Centers for Medicare & Medicaid Services (CMS) has released its final National Coverage Determination (NCD) for RADs and HMVs used in treating chronic respiratory failure due to COPD. While the rule potentially expands access to bilevel ST therapy (RADs), it also introduces complex compliance requirements, tighter usage criteria, and increased documentation burdens—without additional reimbursement.

Give your business an advantage over the competition.

Become a Member