SUBJECT: Comments on Proposed LCD DL 35076 Stereotactic Radiation Therapy:
Stereotactic Radiosurgery (SRS) and Stereotactic Body Radiation Therapy
(SBRT)
Dear Ms. Muir:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), we appreciate the opportunity to provide our comments on the National
Government Services, Inc. (NGS) Local Coverage Determination (LCD) DL 35076 Stereotactic Radiation
Therapy: Stereotactic Radiosurgery (SRS) and Stereotactic Body Radiation Therapy (SBRT).
Support for Additional Indication for SRS
The AANS and the CNS support the proposed change to the LCD DL 35076 to add “choroidal and other
ocular melanomas” to the list of covered indications for SRS. The literature cited in the draft LCD is
excellent, and clearly demonstrates the efficacy and safety of SRS for this indication, for appropriately
selected patients.
Coding and Reimbursement for SRS
Neurosurgeons are the leaders in SRS care, and the AANS and the CNS have worked with policymakers
for many years to help ensure that neurosurgical patients have access to this important treatment when
clinically indicated. Below are the appropriate CPT codes used by neurosurgeons when performing
SRS.
Read full letter here
