FMA urges FCSO to retire local coverage article on complex drug administration
By Jarrod Fowler, MHA, FMA Director of Health Care Policy and Innovation |  Updated Sept. 22, 2022

In August, the FMA passed Resolution 22-404 by way of the House of Delegates gathering at our 2022 Annual Meeting. Among other things, this resolution calls for the FMA to oppose Local Coverage Articles (LCAs) that could have the effect of restricting coverage or access without providing data and evidentiary review or without issuing associated Local Coverage Determinations (LCDs) and following required stakeholder processes. In short, the resolution calls for the FMA to oppose inappropriate LCAs that could harm the practice of medicine in Florida. This would include LCA A59074 on complex drug administration, which the FMA and the Florida specialty provider associations that authored and supported this resolution believe is not a simple correction in coding.

Recent conversations between Centers for Medicare & Medicaid Services leadership and specialty physician association leaders from Florida and elsewhere around the country — including the AMA, which passed its own resolution in support — have led CMS to recognize that the drugs contained within LCA A59074 should be considered complex. This decision was issued recently to all Medicare Administrative Contractors (MACs).

WPS Government Health Administrators (WPS GHA) has confirmed this decision by issuing a retirement date (Aug. 12, 2022) for its LCA titled Billing and Coding: Complex Drug Administration Coding A58544. The FMA is asking First Coast Service Options (FCSO) to quickly follow the directions provided by CMS and issue a retirement to LCA A59074. Read the FMA’s letter to FCSO Executive Contractor Medical Director Juan Schaening, MD, on this important topic.