LCD Reference Article Response To Comments Article

Response to Comments: Cervical Fusion

A59772

Expand All | Collapse All
Draft Article
Draft Articles are works in progress and not necessarily a reflection of the current billing and coding practices. Revisions to codes are carefully and thoroughly reviewed and are not intended to change the original intent of the LCD.

Document Note

Note History

Contractor Information

Article Information

General Information

Source Article ID
N/A
Article ID
A59772
Original ICD-9 Article ID
Not Applicable
Article Title
Response to Comments: Cervical Fusion
Article Type
Response to Comments
Original Effective Date
08/01/2024
Revision Effective Date
N/A
Revision Ending Date
N/A
Retirement Date
N/A

CPT codes, descriptions, and other data only are copyright 2023 American Medical Association. All Rights Reserved. Applicable FARS/HHSARS apply.

Fee schedules, relative value units, conversion factors and/or related components are not assigned by the AMA, are not part of CPT, and the AMA is not recommending their use. The AMA does not directly or indirectly practice medicine or dispense medical services. The AMA assumes no liability for data contained or not contained herein.

Current Dental Terminology © 2023 American Dental Association. All rights reserved.

Copyright © 2024, the American Hospital Association, Chicago, Illinois. Reproduced with permission. No portion of the AHA copyrighted materials contained within this publication may be copied without the express written consent of the AHA. AHA copyrighted materials including the UB‐04 codes and descriptions may not be removed, copied, or utilized within any software, product, service, solution, or derivative work without the written consent of the AHA. If an entity wishes to utilize any AHA materials, please contact the AHA at 312‐893‐6816.

Making copies or utilizing the content of the UB‐04 Manual, including the codes and/or descriptions, for internal purposes, resale and/or to be used in any product or publication; creating any modified or derivative work of the UB‐04 Manual and/or codes and descriptions; and/or making any commercial use of UB‐04 Manual or any portion thereof, including the codes and/or descriptions, is only authorized with an express license from the American Hospital Association. The American Hospital Association (the "AHA") has not reviewed, and is not responsible for, the completeness or accuracy of any information contained in this material, nor was the AHA or any of its affiliates, involved in the preparation of this material, or the analysis of information provided in the material. The views and/or positions presented in the material do not necessarily represent the views of the AHA. CMS and its products and services are not endorsed by the AHA or any of its affiliates.

CMS National Coverage Policy

N/A

Article Guidance

Article Text

This article addresses comments received by Noridian Healthcare Solutions, CGS Administrators, National Government Services, Palmetto GBA, WPS Government Health Administrators, First Coast Service Options and Novitas Solutions during the open comment period for this policy.

Response To Comments

Number Comment Response
1

A comment was received from a physician/medical director. He states:

  1. “Myelopathy is not caused by cervical nerve root impingement. If myelopathy is present, then the exception to conservative therapy requirements in Section B for symptomatic cervical canal stenosis would suffice.” He recommends removing Myelopathy class III or above from the exceptions to conservative therapy for decompression of symptomatic cervical nerve root impingement section.
  2. Cauda equine syndrome is not possible in relation to the cervical spine; it is a lumbar spine condition and has no place in a cervical spine fusion LCD. I would recommend removal of cauda equina syndrome. 

Thank you for your comments. We agree nerve root impingement does not cause myelopathy; however, it may be associated with cervical myelopathy or myeloradiculopathy. The wording has been adjusted in the LCD to clarify this. We also agree that cauda equina is rare below L1 and above the thoracic spine, however, it can occur at any level of the spinal cord as lumbar and sacral nerve roots go through the cervical canal- to clarify this distinction cauda equina was replaced with loss of bowel or bladder function due to cervical spinal cord compression in the LCD.  

2

The Medical Advisory Group of Chiro Congress submitted comments and a white paper. They state that in development of the CAC they appreciated the effort to include a wide array of providers and the addition of physical therapy to the panel, but felt we omitted the potential contribution from chiropractors.

Thank you for your comments. Your point is well received, and we will consider the addition of Doctor of Chiropractic to a future panel of experts. 

3

A chiropractor submitted a recent review on the role of chiropractic care for disc herniation and cervical radiculopathy prior to consideration of cervical fusion. He requests spinal manipulation (Chiropractic therapy) be added to the list of conservative treatment to be tried prior to cervical fusion.

Another chiropractor who is a CAC member for WPS sent a letter to express support for the inclusion of spinal manipulation as one of the conservative options prior to proceeding with cervical fusion with the Clinical Compass White paper as evidence of potential benefit.

Thank you for your comments. Spinal manipulation is included under the list of conservative treatments to be utilized prior to proceeding with cervical fusion. See the definition of conservative therapy within the LCD. We list all potential interventions and do not require specific ones due to lack of comparative studies on these options. 

4

HCA Regulatory Compliance Support request clarification of Under Limitations, for item 1 in the section “Exceptions to conservative therapy requirement for decompression of symptomatic cervical nerve root impingement:”, which scale is being referenced in relation to “Cervical myelopathy class III or above”.

For Indication C.4. “Deformities that include the cervical spine including when3:”, the last criteria should be revised to “OR progression of deformity” rather than “AND progression of deformity”. Research published via the ISSG has demonstrated severe disability associated with cervical deformities regardless of deformity progression. Attached are published references showing threshold values for pain and disability for cervical deformity which delineates that one does not need to have deformity progression for pain and disability, the deformity alone can cause pain and disability without progression. Two articles were submitted.

Thank you for your comments. The classification system described by Ranawat can be found in the Evidence Section of the LCD under “Cervical Myeloradiculopathy (Mixed).” Based on the submitted literature we agree there may be a role for correction of cervical deformity in the presence of pain and disability without deformity progression; therefore the “AND” has been changed to “OR.” 

5

A comment was received that the limitation of asymptomatic myelopathy (regardless of severity on imaging findings) as not reasonable and necessary should be removed. The commenter states there are situations when a clinically significant, even if asymptomatic myelopathy, may require surgical intervention and should be left to provider discretion. 

Thank you for your comments. There was not literature to support a role for surgical intervention in this population. If there is literature to expand to this group it can be submitted through the LCD reconsideration process. 

N/A

Coding Information

Bill Type Codes

Code Description

Please accept the License to see the codes.

N/A

Revenue Codes

Code Description

Please accept the License to see the codes.

N/A

CPT/HCPCS Codes

Please accept the License to see the codes.

N/A

CPT/HCPCS Modifiers

Group 1

Group 1 Paragraph

N/A

Group 1 Codes

N/A

N/A

ICD-10-CM Codes that Support Medical Necessity

Group 1

Group 1 Paragraph

N/A

Group 1 Codes

N/A

N/A

ICD-10-CM Codes that DO NOT Support Medical Necessity

Group 1

Group 1 Paragraph

N/A

Group 1 Codes

N/A

N/A

ICD-10-PCS Codes

Group 1

Group 1 Paragraph

N/A

Group 1 Codes

N/A

N/A

Additional ICD-10 Information

Bill Type Codes

Code Description

Please accept the License to see the codes.

N/A

Revenue Codes

Code Description

Please accept the License to see the codes.

N/A

Other Coding Information

Group 1

Group 1 Paragraph

N/A

Group 1 Codes

N/A

N/A

Coding Table Information

Excluded CPT/HCPCS Codes - Table Format
Code Descriptor Generic Name Descriptor Brand Name Exclusion Effective Date Exclusion End Date Reason for Exclusion
N/A N/A
N/A
Non-Excluded CPT/HCPCS Ended Codes - Table Format
Code Descriptor Generic Name Descriptor Brand Name Exclusion Effective Date Exclusion End Date Reason for Exclusion
N/A

Revision History Information

Revision History Date Revision History Number Revision History Explanation
N/A

Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
Related Local Coverage Documents
LCDs
L39770 - Cervical Fusion
Related National Coverage Documents
N/A
SAD Process URL 1
N/A
SAD Process URL 2
N/A
Statutory Requirements URLs
N/A
Rules and Regulations URLs
N/A
CMS Manual Explanations URLs
N/A
Other URLs
N/A
Public Versions
Updated On Effective Dates Status
06/03/2024 08/01/2024 - N/A Currently in Effect You are here

Keywords

N/A