LCD Reference Article Response To Comments Article

Response to Comments: Cervical Fusion

A59803

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Article ID
A59803
Original ICD-9 Article ID
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Article Title
Response to Comments: Cervical Fusion
Article Type
Response to Comments
Original Effective Date
06/27/2024
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The following are the comment summaries and contractor responses for First Coast Proposed Local Coverage Determination (LCD) DL39799 Cervical Fusion which was posted for comment on February 15, 2024, and presented at the August 16, 2023 Multi-MAC Contractor Advisory Committee (CAC) Meeting and February 29, 2024 Open Meeting. All comments were reviewed and incorporated into the final LCD where applicable .

Response To Comments

Number Comment Response
1

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.  

2

HCA Regulatory Compliance Support request clarification 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 when:”, 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. Two articles were submitted 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. 

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.”

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Associated Documents

Medicare BPM Ch 15.50.2 SAD Determinations
Medicare BPM Ch 15.50.2
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