On Friday, July 12, AAPM&R submitted comments to several Medicare Administrative Contractors (MACs) in support of substantial changes to the draft local coverage determinations (LCDs) and coding and billing articles on botulinum toxin injections released for comment in June. If implemented, the draft LCDs and articles will have a devastating impact on patient access to critically-needed botulinum toxin treatment. These new policies seek to limit the reimbursable diagnoses, reduce the maximum dosage for certain toxins, as well as propose other changes to coverage which are inconsistent with the standard clinical use of botulinum toxin. Recognizing the critical role our members play in spasticity treatment, AAPM&R mobilized quickly and crafted forceful comments to the MACs, referencing our own recently-published clinical guidance as well as other supporting literature.
Sign-on Letter with 13 Patient and Provider Organizations
Despite an extremely limited comment period, AAPM&R responded with strongly-worded comments and also spearheaded a coalition letter outlining numerous arguments against the LCDs. This letter, co-led by the American Academy of Neurology (AAN) and the American Academy of Ophthalmology (AAO), was signed by 13 additional groups including many patient-based organizations. The draft LCDs address numerous conditions in addition to spasticity and dystonia, such as migraine and blepharospasm. Coordinating the coalition letter was a critical step in presenting a unified voice opposing the proposed coverage limitation across the “House of Medicine.”
Fighting Against Physician Fee Cuts and For Improved PM&R Physician Payment
A key advocacy priority, AAPM&R remains committed to pursuing fair reimbursement and appropriate coverage for physician-led care. By consistently educating payers on the value of health and function, the Academy is helping establish our members as a critical piece of the new value-driven healthcare delivery landscape and fighting back against policies that restrict access to care for patients.
The individualized letters linked below were sent to each MAC with a draft policy on this issue.
- AAPM&R Comments to Medicare Administrative Contractors on Draft Local Coverage Determination on Botulinum Toxin Injections
- AAPM&R, AAN and AAO Lead Coalition Comment Letter to Medicare Administrative Contractors on Draft Local Coverage Determination on Botulinum Toxin Injections
Academy staff will be monitoring the MAC websites for updates and will notify members once a final policy is announced. To date, draft LCDs have not been published by either Novitas or First Coast Service Options.
Related, AAPM&R has been working diligently to establish PM&R’s overall value in treating individuals with spasticity. Read on to learn more about the Academy’s recent efforts and how you can get involved.
AAPM&R’s Spasticity Guidance
AAPM&R recently released spasticity guidance to assist PM&R providers in the management of spasticity. This guidance, published in the PM&R Journal, provides a condensed review of evidence for the assessment and management of spasticity.
AAPM&R also has this consensus statement available as an outcome from our 2022 Spasticity Summit, which focuses on the barriers and solutions to care access, patient and caregiver support, and clinical capacity and capability for patients with spasticity.
Outpatient Mastermind Series: Developing a Successful Spasticity Practice
AAPM&R held an informative webinar last month where a panel of four Academy leaders shared their insights on spasticity practice, focusing on practice management strategies for PM&R physicians at any stage of practice. Panelists discussed how they started their practices, challenges they’ve encountered and strategies for achieving success across a range of practice settings. Access the full recording here.
Spasticity Member May Session Recording
Couldn’t make it to the Spasticity Management Member May session, Baclofen Pump Troubleshooting 101 and Beyond? No worries. Academy members can now access the full recording here, with the opportunity to earn up to 1.25 CME credits. This session was one of more than 25 free educational and networking sessions hosted as part of AAPM&R’s Member May. Find more on AAPM&R’s Online Learning Portal—search “Member May 2024.”
How to Get Involved
Our work continues in this space, with AAPM&R asserting a leadership role to address gaps in spasticity management and patient care.
Members with questions may contact Academy staff at healthpolicy@aapmr.org.
Additional AAPM&R Advocacy Resources