Comment Letter

Neurosurgery Submits Comments to First Coast Regarding Neurostimulator LCD

  • Reimbursement and Practice Management

Juan L. Schaening-Perez, MD
First Coast Service Options
Attn: Medical Policy and Procedures
532 Riverside Ave, ROC 19T
Jacksonville, FL 32202-4914
Via email to: ProposedLCDComments@fcso.com

Subject: Proposed Local Coverage Determination (LCD): Nerve Stimulators for Chronic Intractable Pain (DL 39406).

Dear Dr. Schaening-Perez:

The AANS and the CNS appreciate the opportunity to comment on the above referenced First Coast Service Options (FCSO) proposed local coverage determination (LCD) policy for spinal cord (SCS) and peripheral nerve stimulation (PNS) for pain (DL 39406). These procedures are increasingly important for reducing pain, disability and opioid use among the Medicare population. The AANS and the CNS are keenly interested in these proposed policies, given their importance to our patients with chronic pain. However, we are concerned that these proposed policies have multiple issues that require correction as they may adversely affect patient care if implemented as they currently stand.

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