Local Coverage Article Response to Comments

Response to Comments: Transcranial Magnetic Stimulation


Expand All | Collapse All

Contractor Information

Article Information

General Information

Article ID
Article Title
Response to Comments: Transcranial Magnetic Stimulation
Article Type
Response to Comments
Original Effective Date
Retirement Date
AMA CPT / ADA CDT / AHA NUBC Copyright Statement

CPT codes, descriptions and other data only are copyright 2022 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 © 2022 American Dental Association. All rights reserved.

Copyright © 2023, the American Hospital Association, Chicago, Illinois. Reproduced with permission. No portion of the American Hospital Association (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.

Article Guidance

Article Text

As an important part of Medicare Local Coverage Determination (LCD) development, National Government Services solicits comments from the provider community and from members of the public who may be affected by or interested in our LCDs. The purpose of the advice and comment process is to gain the expertise and experience of those commenting.

We would like to thank those who suggested changes to the Transcranial Magnetic Stimulation Local Coverage Determination. The official notice period for the final LCD begins on February 9, 2023, and the final determination will become effective on April 1, 2023.

Response To Comments


The following comments were received from members of the Minnesota Psychiatric Society (MPS) in support of approving coverage of TMS for OCD:

  • OCD is a condition which tends to start in adolescence and it tends to be a chronic and lifelong condition which typically causes continuous symptomatology rather than episodic. It can cause significant and enduring distress and disability.
  • Medication options that currently exist are less than ideal, often have to be prescribed at relatively high doses (often at higher doses than needed for depressive disorders or other anxiety disorders). Often times combination therapy with up to several medications at a time is required.
  • Response to medications is often suboptimal and the medication options carry a significant side effect burden.
  • Neurosurgery can be helpful for individuals with refractory disease, but it is invasive and carries a higher risk than TMS.
  • TMS has minimal to no side effects
  • The FDA has now approved two coils for TMS for OCD, H7 and Cool D-B80.
  • Patients with OCD may also suffer from major depressive disorder and both conditions can be responsive to treatment with the H-7 coil
  • Psychiatrists in MPS find that TMS provides an invaluable tool that is effective and well tolerated.

NGS appreciates your statements collated from the group’s membership on Obsessive Compulsive Disorder (OCD) and Transcranial Magnetic Stimulation (TMS). However, there is no literature submitted in support of your comments.

See Internet Only Manual 100-08, Medicare Program Integrity Manual, Chapter 13 – Local Coverage Determinations, Section 13.2.3. Acceptance by individual health care providers, or even a limited group of health care providers, does not indicate general acceptance of the item or service by the medical community.


Two comments were received from BrainsWay employee Scott Blackman. The first was a request received to re-evaluate the evidence for Deep TMS (dTMS) for OCD only and to avoid looking at information that was not on topic, while also adding in four additional studies that were not included in the review but were submitted in an evidence update for the reconsideration of 8/1/2022. The second request were comments received to evaluate the LCD’s evidence analysis and to request a re-evaluation of the Deep TMS evidence for OCD. The request contained many suggested articles for review by BrainsWay without full copies of the literature.

The request to avoid looking at other sources of information is reasonable, and the changes needed were made to the Final by removing any articles not about dTMS and OCD. The evidence was reviewed, changes were made and reflected in the final version.

Concerning the second request, while we appreciate the many articles of literature given with extensive summaries for all, unfortunately, many of the articles had significant conflicts of interest, including funding by BrainsWay. The remaining literature that did not have significant COI, was not well validated, had very small samples and did not provide strong evidence for dTMS for OCD but did encourage for further studies to be done. Thank you in advance.

Associated Documents

Related Local Coverage Documents
L33398 - Transcranial Magnetic Stimulation
Related National Coverage Documents
Public Versions
Updated On Effective Dates Status
02/02/2023 04/01/2023 - N/A Currently in Effect You are here