The OIG issued their August Work Plan. The update includes plans to evaluate whether Medicare paid physicians for hyaluronic acid knee injections in accordance with Medicare requirements.
The FDA and CMS have published strict indications for use and coverage including, but not limited to:
- Symptomatic osteoarthritis (OA) of the knee with pain that interferes with functional activities
- Diagnosis of OA supported by radiographic evidence
- Trial and failure of at least 3 months conservative therapy including:
- Non-pharmacologic therapy (e.g., weight management, physical therapy, exercise)
- Pharmacologic therapy (e.g., acetaminophen, NSAIDS)
- Failure or contraindication to intra-articular glucocorticoid injections
There are also strict indications and coverage for repeat injections including:
- At least 6 months have elapsed since prior series of injections
- Patient still meets initial criteria
- Patient has experienced improvement in pain and functional capacity
If you perform hyaluronic injections, we recommend reviewing all the FDA and CMS requirements and conducting audits to ensure your documentation supports medical necessity and coverage requirements.
The HBE team of experts is available to assist you with your auditing needs.
The OIG Work Plan may be found here: https://oig.hhs.gov/reports-and-publications/workplan/updates.asp
The CMS coverage database for applicable local coverage articles and determinations (LCAs and LCDs) may be found here: https://www.cms.gov/medicare-coverage-database/search.aspx