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Richey v. Shalala; In re Richey
No. W00CA025 (W.D. Tex. filed Feb. 1, 2000)). ; Clearinghouse Number: 52362
Description
Medicare to Cover Lung Volume Reduction Surgery Because It Was Safe, Effective, and "Reasonable and Necessary"
Abstract
The administrative law judge (ALJ) held that payment for
claimant’s lung volume reduction surgery (LVRS) was payable
under Medicare part B of title XVIII of the Social Security Act
because it was not considered an experimental procedure, had been
proven safe and effective, and was "reasonable and
necessary" for appellant. The claimant’s bill had to be
paid despite a national coverage determination that LVRS generally
was not a Medicare-covered service. Doctors determined
claimant—with a history of emphysema and disabled for
purposes of social security—to be an excellent candidate for
LVRS. He had the surgery, which dramatically improved his breathing
and functional level. Medicare had ordered that a safety and
effectiveness study be performed regarding LVRS but refused
coverage of the surgery before receiving the study results. A fair
hearing officer affirmed denial of coverage because the surgery was
experimental. The ALJ, relying on a Medicare covered issues manual
section stating that LVRS was not "generally" covered
because of insufficient medical evidence on its safety and
effectiveness, found that this indicated that in some cases the
surgery would be covered, given that it was generally safe and
effective. In this case the indication for LVRS was well
documented, as was its safety and effectiveness, in well-known
medical journals and by qualified physicians.
Additional Information
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