Tuesday, June 23, 2026

LCD Manual, Chapter 13, the Obscure "Exhibit 3" for CAC Membership

 Older CAC instructions ("PIM Chapter 13, LCDs") refer to Exhibit 3, which is hard to find today.  It is a listing of state-level CAC specialists.   

See one example here:

https://www.cms.gov/regulations-and-guidance/guidance/transmittals/downloads/r71pi5.pdf

BQ file copy, 2004 CMS 0409 PIM Ch 13 LCDs Exhibit 3 here R71PI5.pdf 

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Yes. I found the legacy CMS Program Integrity Manual Exhibits PDF online, in CMS Transmittal R71PI5 from April 9, 2004. It contains “Exhibit 3 — Description of CAC Members”, which is exactly the missing companion to the old PIM Chapter 13 CAC section. The exhibit begins on PDF page 9 of the transmittal. (Centers for Medicare & Medicaid Services)

The key language is quite revealing. Exhibit 3 says Medicare defined “physicians” for CAC purposes as doctors of medicine, osteopathy, dental surgery/dental medicine, chiropractors, podiatrists/surgical chiropodists, and optometrists — and then stated bluntly: “Do not include other practitioners on this committee.” It also said carriers should select committee representatives from names recommended by state medical societies and specialty societies. (Centers for Medicare & Medicaid Services)

The exhibit then instructed carriers to try to include physician representatives from state medical/osteopathic societies, the National Medical Association where applicable, Medicare managed care organizations, and physician representatives for chiropractic, maxillofacial/oral surgery, optometry, and podiatry. (Centers for Medicare & Medicaid Services)

The specialty list in the 2004 Exhibit 3 included:

Allergy; Anesthesia; Cardiology; Cardiovascular/Thoracic Surgery; Dermatology; Emergency Medicine; Family Practice; Gastroenterology; Gerontology; General Surgery; Hematology; Internal Medicine; Infectious Disease; Medical Oncology; Nephrology; Neurology; Neurosurgery; Nuclear Medicine; Obstetrics/Gynecology; Ophthalmology; Orthopedic Surgery; Otolaryngology; Pathology; Pediatrics; Peripheral Vascular Surgery; Physical Medicine and Rehabilitation; Plastic and Reconstructive Surgery; Psychiatry; Pulmonary Medicine; Radiation Oncology; Radiology; Rheumatology; and Urology. (Centers for Medicare & Medicaid Services)

It also had separate sections for a clinical laboratory representative, two beneficiary representatives — one representing elderly issues and one representing disabled beneficiaries — and “other organizations,” including the State Hospital Association, QIO medical director, intermediary medical director, Medicaid medical director or designee, and a representative of an administrative-practice organization such as MGMA. (Centers for Medicare & Medicaid Services)

One important later wrinkle: CMS issued Transmittal R106PI in March 2005 specifically to add interventional pain management specialists to CAC membership. The transmittal says carriers were required to maintain CACs and that certain specialties “must include interventional pain management specialists”; the business requirement stated that contractors shall include one physician representative from the clinical specialty of interventional pain management on their CAC.

So the best reconstruction is:

2004 Exhibit 3 = the long baseline roster of required/recommended CAC specialties and organizational representatives.

2005 R106PI = a targeted amendment adding interventional pain management to the CAC specialty representation list.

This is a useful find because it confirms that the old CAC was not just a vague advisory body. It was a highly specified, state/specialty-society roster model — much closer to a standing medical parliament for the carrier’s state or jurisdiction than to the later 2019-style evidence panel.