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DME MACs Propose LCD for Topical Oxygen to Treat Diabetic Foot Ulcers
Comments are being accepted through Sept. 5.

July 24, 2026 by Laurie Watanabe

The two Medicare DME MAC contractors have proposed a local coverage determination (LCD) for Medicare beneficiaries with diabetic foot ulcers.

Under the proposed LCD, released by CGS Administrators (jurisdictions B and C) and Noridian Healthcare Solutions (jurisdictions A and D) on July 23, Medicare would cover topical oxygen therapy to treat diabetic foot ulcers “that have failed to heal with four consecutive weeks of optimized diabetic foot ulcer care.”

Medicare’s coverage would be part of its oxygen and oxygen equipment benefit. A number of criteria would need to be met for a patient to qualify, including that “the treating practitioner has completed an in-person visit with the beneficiary.”

To qualify for the topical oxygen therapy, the patient must have a non-gestational type of diabetes mellitus with a diabetic foot ulcer that “has not experienced at least 50% reduction in ulcer area despite at least four consecutive weeks of optimized diabetic foot ulcer care.”

The patient must also meet certain glycosylated hemoglobin numbers and adequate arterial perfusion to support healing.

The treating practitioner would have to complete an in-person visit for each additional month of topical oxygen therapy after the first month, and the DME MACs are additionally proposing to require improvements such as a reduction in ulcer area or improvement in diabetic foot ulcer classification.

“We are soliciting comments on the proposed LCD from stakeholders (including, but not limited to, clinicians, manufacturers, suppliers and other parties who care for Medicare beneficiaries),” the DME MACs said. “You should be very specific in your comments and, if possible, offer suggestions that may address your concerns. You should provide an evidence-based rationale for your comments and attach any full-text references from the published clinical literature (for example, peer-reviewed journals, clinical society guidelines, etc.) that were not included in the bibliography of the proposed LCD.”

Comments must be submitted electronically by Sept. 5.

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