September 27, 2022

As the Medicare Jurisdiction L and H DME MAC considers creating a uniform immune globulin (Ig) local coverage determination (LCD), NHIA submitted comments pointing out the advantages of home-based administration of subcutaneous Ig (SCIG) for chronic inflammatory demyelinating polyneuropathy (CIPD).

The association noted that SCIG requires more frequent dosing than IVIG and therefore requires the beneficiary to travel much more frequently, which can be burdensome and often not possible for those in rural areas. Because most beneficiaries who choose SCIG do so because it can be self-administered in their home, NHIA contends that it is not necessary to add SCIG coverage to the physician office site of care. The vast majority of beneficiaries who choose the SCIG option do so because it can be self-administered in their home, a contributing factor in their health-related outcomes.

If the DME MAC chooses to do so, NHIA notes that it is critical that beneficiaries be informed of the site of care options available to them as required under the Physician Fee Schedule.