SUBJECT: Comments on Proposed LCD DL 33569 for Percutaneous Vertebral
Augmentation (PVA) for Osteoporotic Vertebral Compression Fracture (VCF)
Dear Ms. Muir:
On behalf of the American Association of Neurological Surgeons (AANS), the Congress of Neurological
Surgeons (CNS) and the AANS/CNS Joint Section on Disorders of the Spine and Peripheral Nerves
(DSPN), we appreciate the opportunity to provide our comments on the National Government Services,
Inc. (NGS) Local Coverage Determination (LCD) DL33569 for Percutaneous Vertebral Augmentation
(PVA) for Osteoporotic Vertebral Compression Fracture (VCF). In our comments below, we reference
the published LCD as well as the March 20, 2019, Multi-jurisdictional Medicare Administrative Contractor
(MAC) Carrier Advisor Committee (CAC) conference call on PVA for Osteoporotic Vertebral
Compression Fracture and other scientific evidence where noted.
PVA has emerged as a minimally invasive surgical treatment option to expedite pain control, improve
quality of life, and reduce morbidity and mortality after osteoporotic compression fracture. Although
some of the early trials of PVA failed to demonstrate clinical benefit over nonoperative management, a
multitude of subsequent studies have demonstrated that PVA is safe, effective and durable.
In response to questions about the clinical literature, a consensus position statement was published in
2014 representing many of the leading professional organizations relevant to PVA.
The position statement supported PVA for the treatment of osteoporotic compression fractures and offered evidence-based guidelines on its proper utilization. The statement represented the views of the Society of
Interventional Radiology (SIR), the American Association of Neurological Surgeons (AANS), the
American College of Radiology (ACR), the American Society of Neuroradiology (ASNR), the American
Society of Spine Radiology (ASSR), the Canadian Interventional Radiology Association (CIRA), the
Congress of Neurological Surgeons (CNS) and the Society of NeuroInterventional Surgery (SNIS).
Furthermore, in 2018, Hirsch et al. introduced a clinical care pathway to facilitate decision-making for
best practices on PVA based on the existing literature.
Read full letter here
