Save the Facet Joint reimbursement

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SPECIAL Action Alert for ISIS Members
Noridian Non Coverage of Lumbar Facet Procedures

ISIS Sample Letter provided for comments to Noridian due by 8/31/2009

Noridian Administrative Services, a major Medicare contractor has recently proposed non-coverage for lumbar facet joint injection and medial branch block CPT codes 64475, 64476, and the corresponding RF neurotomy codes 64622 and 64623. If this proposed policy is implemented, these facet-related CPT codes with no longer be covered and reimbursed by Medicare in the affected states (Alaska, Arizona, Montana, North Dakota, Oregon, South Dakota, Utah, Washington, Wyoming, etc.). A non-coverage determination by Noridian may subsequently be utilized as a basis for a National non-coverage determination by CMS and will thus likely have NATION-WIDE IMPLICATIONS.

The LCD Policy can be accessed at:


NOTE - You must agree to the Noridian Disclosure Agreement at the bottom of the page by clicking <Accept> before you will able to view the LCD Draft.

Over the last couple months, leaders of ISIS, NASS, AAPM, AAPM&R, SIR, and other societies have worked to develop a consensus response requesting immediate removal of these CPT codes from the proposed non-coverage list. Additionally, a scientifically-based Local Coverage Determination (LCD) proposal has been drafted and is supported by the ISIS Board and aforementioned societies. We believe the proposed multi-society LCD will address the issues of overutilization, miscoding, and potential fraudulent coding highlighted in the Office of the Inspector General (OIG) report regarding facet injections released in September 2008. The consensus proposal would also support proposed CPT edits requiring image guidance for these procedures, and maintain appropriate access for Medicare beneficiaries with lumbar facet joint pain.
YOUR INVOLVEMENT IS NEEDED NOW. THE DEADLINE TO RESPOND IS AUGUST 31 AT 12 NOON PST, after which time the comment period ends and Noridian will cease accepting letters and comments.

A sample letter is provided below that can be individualized. We suggest keeping your response brief, professional and factual.

EMAIL your response or letter to:

Noridian Administrative Services LLC Contractor Medical Director(s)
Policy Development - Medicare Part B - Drafts
900 42nd Street S.
P.O. Box 6740
Fargo, ND 58108
Email: [email protected]

More information for reference is available by clicking on the following links:
Proposed LCD for Noridian's consideration
A PowerPoint presentation of consolidated evidence with an appeal that complements the other documents
SAMPLE LETTER for ISIS Members: We encourage you to modify or re-write this in your own voice and practice letterhead. Please remember to sign the letter. Click here for the Word version. This letter can be emailed to: [email protected]
[Insert Date]

Noridian Administrative Services, LLC
Attn: Part B Medical Director
P.O. Box 6740
Fargo ND 58108-6740

Dear Medical Directors:

REGARDING: Noridian proposed non-coverage (DL24471) of CPT codes 64622, 64623, 64475 and 64476 (lumbar facet blocks and denervation procedures)

As a member of International Spine Intervention Society (ISIS), I stand with more than 3,000 Board Certified spine care specialists, including anesthesiologists, physiatrists, radiologists, neurosurgeons, and orthopedic spine surgeons, and request the immediate removal of the lumbar facet joint/nerve injection and RF (denervation) codes (64475-76 & 64622-23) from your proposed non-coverage list.

As a physician who specializes in the diagnosis and treatment of spine pain on a daily basis, I find it inconceivable that the above referenced CPT codes (64475-76, 64622-23), which have proven diagnostic and therapeutic value, would be removed from coverage to the detriment of Medicare beneficiaries.

If the proposed non-coverage policy is implemented, it will limit the ability of providers to adequately evaluate and subsequently treat patients who suffer with facet joint mediated pain and the associated debilitation and impairments that result. This will contribute to continued misdiagnosis of low back pain in the affected population, over-utilization of other unnecessary diagnostic tests, perpetuation of ineffective therapies or inappropriate treatment, including surgical interventions, and contribute to escalating health care costs in this patient population.

ISIS fully supports efforts to optimize resource utilization and reduce inappropriate expenses by addressing the concerns noted in the OIG report (September 2008, OEI-05-07-00200) regarding the overutilization and inappropriate coding of these procedures.

I believe the proposed LCD and response submitted on behalf of our ISIS membership is appropriate and recommendations outlined therein should be implemented by Noridian.

Respectfully Submitted,

[Insert Name, Specialty, Address]