Medicare Contractors Release Draft Botulinum Toxin Policies – Urgent Action Needed by Members Who Treat Spasticity

Members & Publications


June 11, 2024

This month, several Medicare Contractors have released highly troubling draft local coverage determinations (LCDs) addressing coverage of botulinum toxin for several conditions including spasticity and dystonia.  The draft LCDs are linked below for your information/review.  We have not seen draft LCDs released by either First Coast Service Options or Novitas Solutions at this time and will update you if those are released. 

CGS Administrators - Draft LCD and Draft Coding and Billing Article
Noridian Healthcare Solutions - Draft LCD and Draft Coding and Billing Article
Palmetto GBA – Draft LCD and Draft Coding and Billing Article
National Government Services – Draft LCD and Draft Coding and Billing Article
WPS Insurance Corporation – Draft LCD

Upon initial analysis, these policies seek to dramatically restrict coverage of botulinum toxin for many conditions relevant to PM&R.  The contractors are accepting comments on the drafts through mid-July.  AAPM&R is developing comment letters to the relevant contractors.  If you would like to provide information to help inform our comments, please share your feedback via email to

Contractors are holding open meetings next week to discuss the botulinum toxin draft LCDs, along with other priority policy areas.  For information about these open meetings, visit the upcoming meetings list on the Medicare website.  We encourage members with concerns about these policies to attend your contractor’s open meeting and/or submit written comments so that the PM&R voice is heard loudly on this important issue. 

Legislation Introduced to Alleviate Impact of Conversion Factor Cut for 2021

Nov 09, 2020

Last month, two bills were introduced in the House proposing solutions to the estimated 10.6% Physician Fee Schedule conversion factor cut expected to go into effect January 1, 2021.  The bills offer some relief to the cut, but do not reflect a comprehensive or long-term solution.  AAPM&R has therefore chosen to remain neutral regarding these bills. 

Your Academy continues to advocate for a permanent solution to the conversion factor cut while maintaining the important payment increases to office and outpatient evaluation and management services.