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.