SUBJECT: Comments on Proposed National Coverage Determination for Acupuncture for
Chronic Low Back Pain (CAG-00452N)
Dear Ms. Jensen:
On behalf of the American Association of Neurological Surgeons (AANS), the Congress of Neurological
Surgeons (CNS), the AANS/CNS Section on Disorders of the Spine and Peripheral Nerves (DSPN) and
the AANS/CNS Section on Pain, we appreciate the opportunity to provide our comments on the Centers
for Medicare & Medicaid Services’ (CMS) National Coverage Determination (NCD) for Acupuncture for
Chronic Low Back Pain (CAG-00452N).
Need for Additional Clinical Data
We believe that in many cases, conservative management is appropriate for patients with chronic pain
before considering surgical intervention, and there may be a role for acupuncture for patients with
chronic low back pain. Therefore, we are not opposed to coverage for acupuncture treatment for
Medicare patients enrolled in clinical trials supported by the National Institutes of Health or in CMSapproved studies meeting Agency for Healthcare Research and Quality (AHRQ) criteria. The data
appear to be conflicting regarding the benefit of acupuncture for chronic low back pain, but it may play
more of a role for acute low back pain. As such, we believe that it is reasonable to support the NCD for
coverage of acupuncture for acute, and possibly chronic, low back pain patients enrolled in clinical trials
Although CMS has received numerous comments from providers stating that acupuncture has been in
existence for thousands of years, anecdotal claims are not equal to scientific evidence.
Read full letter here
