YOUR COMMENTS, PLEASE!

This year, the Centers for Medicare and Medicaid Services (CMS) has made a proposal to cover acupuncture treatments for chronic low back pain (CAG-00452N).CMS has defined chronic low back pain (cLBP) as:

  • Lasting 12 weeks or longer; 

  • nonspecific, in that it has no identifiable systemic cause (i.e., not associated with metastatic, inflammatory, infectious, etc. disease); 

  • not associated with surgery within 12 weeks of enrollment in the study; and 

  • not associated with pregnancy.

     

Until THIS THURSDAY (8/15/19) CMS is accepting public comment on this proposal. Click here to access their online comment form. (Note: you have to agree to their comment policy, by checking a box above the comment form to post a comment.)

For a bunch of reasons it would be great for CMS to hear from POCA folks. 

  1. It's super easy- all you do is click the link above, click a box, put your name, org. and comment, and hit send!

  2. If CMS covers acupuncture for this condition, many more people will gain access to a treatment that we already see helping people over and over again in our clinics. This might not mean more biz for POCA clinics (what does medicare billing look like???!!!) but it would simply provide more care.

  3. By treating high volumes of patients, for many years and even decades many POCA punks have a gained a qualtitative understanding of how what we do affects people's lives and ability to function, and with a focus on access and affordability. Apparently other researchers have noticed this qualtitative piece and have done studies looking at not only the affordability and access parts, but the relationship between treatment context and outcomes. 
    CMS wants to hear about un-published evidence. Heck- who knows maybe they want somewhere to direct patients that aren't able to get the care through them yet!

  4. Who knows- maybe the want data on acupuncture's safety record.

  5. As one of the largest constituencies of the acupuncture profession, community acupuncturist and/or POCA members are not well represented in the comments for this CMS proposal. Be sure to include POCA as your organization in the comment form. 

  6. A POCA clinic (or a few of them) could provide someone wishing to study the effects of acupuncture on cLBP the unique opportunity of having a large patient base that could make it easier to do get good data. There probably aren't any/many clinics that could conduct their own research, but maybe something could happen through some of our community healthcare partnerships; we could provide large data sets, and competent practitioners, and because POCA Co-op cares about access- we could eventually figure out a way to do Medicare/Medicade billing, or at the very least be glad that there are CMS partners that could provide acupuncture that was covered. 

 

As a last point of inspiration:
The board of the American Society of Acupuncture (ASA) has sent a letter to CMS and also made a call for comments to their members to weigh in on a specific request that they have made to CMS that this proposal to include “licensed acupuncturist” as one of the specifically named professionals (rather than only “auxiliary personnel”) who can administer acupuncture in a study, and further, that the requirement to have a “physician, physician assistant, or nurse practitioner/clinical nurse specialist,” act in a supervisory role for any “auxiliary personnel.” 

I can see the ASA's point in wanting acupuncturists to be named specifically as providers and can take the inference that having other licensed professionals supervise us in a clinical trial could set a precedent for legislation elsewhere to require physician or other referral for acupuncture treatment. I don't think that is what CMS is intending here. Still, this is an important thing to note and comment on since, if you recall the Veterans Health Administration just made it possible to hire acupuncturists, only if you have current NCCAOM certification or “diplomate” status.

Veteran Health Administration's choice to limit practitioners to those with active NCCAOM status only ultimately may decrease access. By definition in most states acupuncturists have to have passed NCCAOM exams to obtain a license. I would want to clarify the ASA's position about L.Ac.s being represented in this proposal by saying that practitioners are qualified by current licensure would suffice in qualifying to participate in CMS approved studies. While I want to see more access and CMS coveage would be great, it wouldn't be great if it provided the NCCAOM the excuse to push more state laws for "active status" which mainly benefits the NCCAOM's coffers. State laws are already written to insure that practitioners are educated and competent, and that practitioners keep current (CEU requirements).

Let's hope that if CMS coverage for acupuncture comes around it happens soon, and with fewer, rather than more restrictions on delivery of care. 

This story was posted on August 12 2019 by crismonteiro.
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Comments

  • August 13 2019 at 7:09 PM
    Roppy writes:

    I support Medicare/Medicaid Coverage of acupuncture treatments for people who suffer from chronic low back pain.

    I practice acupuncture in a low cost/high volume Community Acupuncture clinic and I have been licensed for 12 years.  Low back pain is the most common reason why patients seek acupuncture. Acupuncture is better when used a first line of defense, rather than a last resort. Acupuncture is minimally invasive and side effects are rare.

    Acupuncture can be used on its own or in conjunction with other kinds of pain treatments or medications, such as cortisone injections.  I have worked with many patients who have been able to reduce their medication when they have regular access to acupuncture.  Some have gotten off of opioid medications entirely. 

    If Medicare/Medicaid should cover acupuncture for those with chronic low back pain, your agency should work with all licensed acupuncturists.  If they have a valid state license, then they are qualified.  Please do not limit this only to acupuncture practitioners who maintain national certification with the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM).  Every licensed practitioner takes the NCCAOM board exam or the very similar California exam.  There is no difference in the quality of care that comes from acupuncturists who pay to keep their national certification and those who do not.

    The Centers for Medicare and Medicaid Services should also consider creating billable codes to cover ear acupuncture for the treatment of Substance Use Disorder, Trauma, and all issues related to behavioral health.  SAMSHA recognizes ear acupuncture as a treatment for SUD in TIP 45 and half of the states in the US allow for non-acupuncturist health providers and lay practitioners to practice ear acupuncture if they are certified by the National Acupuncture Detoxification Association or equivalent training.

    Thank you for taking my input.

      3 likes
  • August 13 2019 at 10:44 PM
    crismonteiro writes:

    Thanks for sending in your comments, Roppy.
    Anyone who’s on social media more than me, please cross post this.
    Thanks!

      0 likes
  • August 15 2019 at 5:48 PM
    urbanapuncture writes:

    Error Message: This document is closed for public comment. Please visit the National Coverage section on the Index page.

      1 likes
    • OpenSourceEverything

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