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The rules say that plans must pay for a medical service or item if regular Medicare would pay for it in this case. 
You can find this rule at 42 Code of Federal Regulations (CFR) Section 422.101. 
 
The rules state that a PCD coded as E0650 or E0651 is covered for both primary and secondary lymphedema in 
beneficiaries with chronic and severe lymphedema when all of the following three requirements are met: 
 
    The beneficiary has a diagnosis of lymphedema as defined above, and 
    The beneficiary has persistence of chronic and severe lymphedema as identified by the documented presence 
of at least one of the following clinical findings: 
        Marked hyperkeratosis with hyperplasia and hyperpigmentation, 
        Papillomatosis cutis lymphostatica, 
        Deformity of elephantiasis, 
        Skin breakdown with persisting lymphorrhea, 
        Detailed measurements over time confirming the persistence of the lymphedema with a history evidencing 
a likely etiology, and 
    In addition to this documented persistence, the lymphedema is then documented to be unresponsive to other 
clinical treatment over the course of a required four-week trial. (See below for trial guidelines.) 
 
A PCD coded as E0650 or E0651 used to treat lymphedema that does not meet all of the requirements above is 
not eligible for reimbursement. Claims will be denied as not reasonable and necessary. 
 
A PCD coded as E0650 or E0651 used to treat edema from causes other than lymphedema is not eligible for 
reimbursement. Claims will be denied as not reasonable and necessary. 
 
A PCD coded as E0652 is not covered for the treatment of lymphedema of the extremities alone even if the 
criteria in this section are met. Claims will be denied as not reasonable and necessary. Refer below to the 
sections III - LYMPHEDEMA EXTENDING ONTO THE CHEST, TRUNK AND/OR ABDOMEN and PCD 
Code Selection for additional information about the limited coverage for PCD coded as E0652. 
 
Four-Week Trial for Lymphedema 
 
A four-week trial of conservative therapy demonstrating failed response to treatment is required. The four-
week trial of conservative therapy must include all of the following: 
 
    Regular and compliant use of an appropriate compression bandage system or compression garment to 
provide adequate graduated compression         Adequate compression is defined as (1) sufficient pressure at the lowest pressure point to cause fluid 
movement, and (2) sufficient pressure across the gradient (from highest to lowest pressure point) to move fluid 
from distal to proximal. The compression used must not create a tourniquet effect at any point. 
        The garment may be prefabricated or custom-fabricated but must provide adequate graduated compression 
starting with a minimum of 30 mmHg distally. 
    Regular exercise 
    Elevation of the limb 
 
When available, manual lymphatic drainage is a key component of conservative treatment as is appropriate 
medication treatment when there is concurrent congestive failure. 
 
At the end of the four-week trial, if there has been improvement, then reimbursement for a PCD is not justified. 
Where improvement has occurred, the trial of conservative therapy must be continued with subsequent 
reassessment at intervals at least a week apart. Only when no significant improvement has occurred in the most 
recent four weeks and the coverage criteria above are still met, may the lymphedema be considered 
unresponsive to conservative therapy, and coverage for a PCD considered. 
 
The medical necessity determination for a PCD by the treating practitioner must include symptoms and 
objective findings, including measurements, to establish the severity of the condition. 
 
The documentation by the treating practitioner of the medical necessity of a pneumatic compression device 
must include: 
 
    The patients diagnosis and prognosis; 
    Symptoms and objective findings, including measurements which establish the severity of the condition; 
    The reason the device is required, including the treatments which have been tried and failed; and 
    The clinical response to an initial treatment with the device 
 
You can find this information in the Local Coverage Determination (LCD) Pneumatic Compression Devices 
L33829. 
 
 
If you want to read these Medicare rules, you can go to this website www.medicareappeal.com.