May 18, 2026

On May 13, AAPM&R submitted comments to several Medicare Administrative Contractors (MACs) in response to Local Coverage Determination (LCD) policies addressing botulinum toxin injections. The Academy’s comments build on prior discussions with these MACs and emphasize the need to ensure Medicare beneficiaries maintain access to medically necessary treatment for spasticity and dystonia.

AAPM&R raised concerns that current dosing limitations may lead to undertreatment of patients with severe spasticity. The letter requests reconsideration of the policy to allow coverage consistent with clinical practice and available evidence. The individualized letters linked below were sent to each MAC with a policy on this issue. 

• AAPM&R Comment Letters to Medicare Administrative Contractors on Local Coverage Determination Policies on Botulinum Toxin Injections (5.13.26)
  • NGS
  • CGS Administrators
  • Noridian Healthcare Solutions
  • Palmetto
  • WPS

CGS is accepting comments on its draft policy through June 6. Thank you to all members who have submitted comments to date. As AAPM&R continues to advance PM&R’s value in treating individuals with spasticity, explore the resources below to support your clinical practice, education, and engagement.

Guidance & Publications

• Spasticity Patient Journey – A Simple Guide to Symptoms, Treatment, and Getting Better
• Understanding Post-Stroke Spasticity: Education for Advancing Provider Awareness
• Key takeaways from the 2024 Spasticity Summit
• Spasticity Guidance (PM&R Journal) - provides a condensed review of evidence for the assessment and management of spasticity.
• Consensus statement (PM&R Journal) - published as an outcome from the 2022 Spasticity Summit, focuses on the barriers and solutions to care access, patient and caregiver support, and clinical capacity and capability for patients with spasticity.

Learning & Continuing Education

• Expert Conversations in PM&R Practice: Spasticity in Focus - This year, the Academy is hosting a webinar series on spasticity exploring clinical, operational, and business strategies—covering everything from assessing and treating spasticity to building an interventional practice, navigating Medicare compliance, integrating multidisciplinary care, optimizing coding and billing, and expanding services through community partnerships and advanced practice providers.
  • Available on the Online Learning Portal (search “Spasticity in Focus”)
• Spasticity Member May Session Recording - Spasticity Under Scrutiny: Medicare Updates, Advocacy Wins, and Compliance Pearls? - Join the AAPM&R Spasticity Member Community this May for a timely and practical discussion on recent Medicare Local Coverage Determinations (LCDs) for botulinum toxin injections and what they mean for physiatrists who care for patients with spasticity.
• STEP Interventional Spasticity Certificate Program – taking place November 10-11, 2026, as a preconference course to Annual Assembly this year!

AAPM&R members can join our Spasticity Member Community on phyzforum.aapmr.org. Members with questions may contact Academy staff at healthpolicy@aapmr.org.