National Coverage Analysis (NCA) View Public Comments

Transcutaneous Electrical Nerve Stimulation for Chronic Low Back Pain

Public Comments

Commenter Comment Information
Roberts, Craig Date: 04/12/2012
Comment:
To Whom It May Concern: [PHI Redacted] I was fortunate enough to meet an exceptionally thorough and knowledgeable business owner who shared her clinical expertise with all of her patients. She used only reliable equipment she had researched independently; looking for the appropriate type of 'wave form' with several types of modes (to avoid accommodation, she said.) That knowledge...not the clinicians, but the concerned business owner who took the time to really instruct her

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VeLure, John Title: Vice President, North American Operations
Organization: Neurotech NA, Inc.
Date: 04/12/2012
Comment:

April 12, 2012

Louis B. Jacques, M.D.
Director, Coverage and Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop C1-09-06
7500 Security Boulevard
Baltimore, MD 21244

RE: Comments to Proposed Medicare Coverage Decision Memorandum for Transcutaneous Electrical Nerve  Stimulation (TENS) for Chronic Low Back Pain (CAG-00429N)

Dear Dr.

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Fordham, Kimberly Title: MD
Date: 04/12/2012
Comment:
I recently learned that it is proposed to discontinue coverage of TENS units. As a family physician who has to treat patients with chronic pain on a daily basis I implore you to reconsider. This country has way too many people addicted to prescription narcotics. The TENS unit provides a healthier, effective option to treat pain that is non-addicting. Please do not make my job any harder than it already is by removing this valuable tool.
Sincerely,
Kimberly Fordham, MD
Radtke, Irene Title: Resident
Organization: The Sarah Community
Date: 04/12/2012
Comment:
It is an interference with the doctor-patient It eliminates patient access to care that has been approved by the DDAfor at least three decades. It interferes with physician's ability to offer alternatives for pain relief. It could increase the use of expensive pain medications.
Amodeo, Anthony Date: 04/12/2012
Comment:
The tens unit helps trememdously and I am against the Proposed Decision Memorandum.Very against it. [PHI Redacted] Thank You
Pettey, Galen Organization: EPT Rehabilitation
Date: 04/12/2012
Comment:

As a therapist with 14 years of experience I have found TENS units to be extremely effective in treating chronic lower back pain. Due to chronic nature of patient's pain, many of them continue to have success with using home TENS units for more than 90 days. It is important that patient's have access to TENS units for more than a 90 day period to continue their improvement in functional ability and ADLs.

In many cases TENS units are the safest and most effective treatment for

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Janowski, Denise Organization: EPT Rehabilitation
Date: 04/12/2012
Comment:

In the physical therapy clinic where I work as a physical therapist assistant we have great success with the use of TENS units for chronic lower back pain. I strongly support continuation of the existing coverage of TENS units

Our patients have had success with home TENS units that they continue to use for more than 90 days. Many patients report improvement in their activities of daily living and function. If TENS units were not covered by Medicare for more than 90 days it

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Schmidt, John Organization: EPT Rehabilitation
Date: 04/12/2012
Comment:

Dear CMS,

I strongly support continuing the existing coverage of transcutaneous electrical nerve stimulation (TENS) for patients with chronic lower back pain.

As a therapist with over 20 years of experience I have found TENS units to be extremely effective in treating chronic lower back pain. Due to chronic nature of patient's lower back issues, many of them continue to have success with using TENS units for more than 90 days. It is important that patient's have

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Herod, John Title: President
Organization: Advantageous MD LLC
Date: 04/12/2012
Comment:
We have been supplying Tens electrotherapy device's since 2009. they have proven to be extremely beneficial to our patients and a drug free alternative for long term care. To deny this non- invasive treatment is counterproductive to the patients goals. We need less dependency on pain medications not more. This treatment option is far more economical than surgery or long term rehabilitation physical therapy.
Means, Megan Title: Patient Care Coordinator
Organization: Medical West Respiratory Services
Date: 04/12/2012
Comment:
Tens is very beneficial for both acute and chronic pain patients. It is a great option to help relieve pain rather then turning to pain Medications. We have many patients that rely on their tens units daily just to get them through the day.
Venturino, Dr Nick Title: Owner
Organization: Healing Hands Chiropractic Center
Date: 04/12/2012
Comment:
TENS has been an integral part of my practice over the last 10 years. Patients desire a drug-free alternative to their pain management. The TENS application has been that safe, effective, drug-free treatment my patients are looking for. Educated patients are very aware of the effects long term use of prescription drugs have on their body and system. Having the option to explore a viable, proven, FDA approved treatment for long term pain management should continue to be a patient’s right.
TURKALP, NORMA Title: MEDICAL CASE MANAGER
Date: 04/12/2012
Comment:

I am commenting on your plans to eliminate coverage of TENS units for treatment of chronic low back pain after 90-days.
I am a Nurse Case Manager who regularly deals with patients with chronic low back pain. Any plans to eliminate coverage of TENS units after 90-days will further limit treatment options for patients. While I understand the need to consider ways to reduce the escalating cost of health care, it is my belief that your plan only targets a small percentage and therefore

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Hughes, Thomas P. Title: Executive Director
Organization: Neurostimulation Device Alliance
Date: 04/12/2012
Comment:

April 12, 2012

Louis B. Jacques, M.D.
Director, Coverage and Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop C1-09-06
7500 Security Boulevard
Baltimore, MD 21244

RE: Comments to Proposed Medicare Coverage Decision Memorandum for Transcutaneous Electrical Nerve Stimulation (TENS) for Chronic Low Back Pain (CAG-00429N)

Dear Dr. Jacques,

On behalf of the Neurostimulation

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Santana, Dr Jorge Title: Owner
Organization: 1 Spine Chiropractic
Date: 04/12/2012
Comment:
TENS for CLBP is both effective and safe. NO long term side-effects, Drug-Free, Non-Addictive…patients benefit from a treatment that will not harm their body or bodily systems. It’s also an option for those patient’s allergic to prescription pain medication. Overall, TENS is one of the best alternative treatments available to patient’s as they address their pain management needs.
Lindell, Regina Title: Patient Care Coordinator
Organization: Medical West Respiratory Central
Date: 04/12/2012
Comment:
TENS has proven to be a low cost, effective way for patients to manage pain. TENS therapy also prevents patients from having to rely on prescription drugs, which can be costly and habit forming.
Valdes, Dr Kevin Title: Partner
Organization: Back to Wellness
Date: 04/12/2012
Comment:
For over 30 years the FDA has approved the use of a TENS as a safe and effective treatment for CLBP. TENS is one of the best treatment alternatives I can provide my patients… knowing that
1) It has NO Side Effects,
2) Its NON-Addictive,
3) It does not have a Long Term affect on other body functions / parts, and
4) provides my patients a cost-effective, safe manner of pain management for their active life. I’m committed to my patient’s well-being. Ultimately, it’s the patient

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Valdes, Dr Michelle Title: Partner
Organization: Back to Wellness
Date: 04/12/2012
Comment:
6) Through my years in practice, I have seen the growth of patients educating themselves relative to their bodies and overall well-being. Patients DO NOT want to take pain medication for their Chronic Lower Back Pain (or any other pain aliments I treat). They want to have options…TENS is one the most effective and safest option available. Restricting this treatment would compromise my patient’s long-term wellness and life style.
Mauro, Craig Title: MD
Organization: burke and Bradley Orthopedics
Date: 04/12/2012
Comment:
I often use TENS electrotherapy for my orthopedic patients. It is an excellent therapy option for pain reduction, reduction of swelling and increase muscle strengthening. Patients who use electrotherapy post-operatively generally require less pain medication and thereby develop less side effects associated with narcotic analgesics.
Garcia, Jr., Mario Title: President and CEO
Organization: EMSI
Date: 04/12/2012
Comment:

April 11, 2012

Louis B. Jacques, M.D.
Director, Coverage and Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop C1-09-06
7500 Security Boulevard
Baltimore, MD 21244

RE Comments to Proposed Medicare Coverage Decision Memorandum for Transcutaneous Electrical Nerve Stimulation (TENS) for Chronic Low Back Pain (CAG-00429N)

To CMS: Via Email and Web

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Spiller, Matthew Title: Physical Therapist
Organization: Payne-Murphy Physical Therapy
Date: 04/12/2012
Comment:

To Whom It May Concern,

I have been a Physical Therapist for 17 years and have used TENS throughout the course of my career most often with orthopedic outpatients.

In my experience with the geriatric population, I estimate TENS has played a significant role in approximately 60-70% of my cases involving chronic low back pain. By a ‘significant role’, I mean TENS helps decrease the pain enough to increase tolerance to ADL, or decrease the pain enough to increase tolerance

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pokita, jacob Title: clinician
Date: 04/12/2012
Comment:
I feel that these units have contributed greatly to patient pain management and in helping to reduces edema in some patients joints which in effect help to restore and help to restore motion. Some patient who have narcotic problems have no other alternative for pain control coverage which this units gives them that option. The unit also helps to manage pain where it is.. centrally located. Many times co-pays and deductibles stop patients from filing medication and try to work thru the pain. We

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SAXON, RICHARD Title: PRESIDENT
Organization: BIOMEDICAL LIFE SYSTEMS, INC.
Date: 04/12/2012
Comment:

TO CMS VIA EMAIL/Web Posting-CAGinquiries@cms.hhs.gov

Louis B. Jacques, MD
Brijet Burton, MPP, MS, PA-C
Sarah Meisenberg, MSPH
Susan Miller, MD
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Medicare Coverage Decision Memorandum for Transcutaneous Electrical Nerve Stimulation (TENS) for Chronic Low Back Pain (CAG-00429N)

Dear Dr. Jacques, Ms. Burton, Ms.

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Watson, PA-C, Naomi Date: 04/12/2012
Comment:

The vast majority of our elderly patients with CLBP love their TENS units. These people have "toughed it out" all of their lives. They seek care when the pain is no longer endurable.

With a TENS unit, most of these patients eliminate the need for pain medicine and lengthen the time between office visits because they can safely and effectively manage flare ups at home.

TENS units improve the quality of life by decreasing pain, reducing the need for pain medicine, reducing

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Berry, Marie Title: Rehabilitation Therapist
Organization: NMS Spine and Joint Institute
Date: 04/12/2012
Comment:
We utilize TENS for patients with spasm, herniation, pain fibromylagia and various other conditions. THe TENS helps to release the pain process and promote healing. We have also utilized the Home TENS units for therapy and pain release.
Bradley, James Title: MD
Organization: UPMC Community Medicine
Date: 04/12/2012
Comment:
Electrotherapy is frequently used in my Orthopedic practice for pain relief as well as muscle strengthening. Not only is electrotherapy cost effective but it also has a very low incidence of side effects or contraindications making it an ideal choice for pain management in the post-operative period. It is a safe alternative to opioid medications that used in the older population may cause undesirable complications.
Tidwell, Katie Date: 04/12/2012
Comment:

There are many reasons why Medicare should continue the coverage of the Tens units. Please see below for a few:

Useful modality for pain management
Safe alternative to medications
In use for decades - low cost and effective
Removal of coverage will drive more pain patients to high risk opioids
Useful in-home means of pain relief and management
No risk of overdose - very low incidence of negative side effects
Limon, Linda Date: 04/12/2012
Comment:
This test would be too costly and cumbersome.
Martinson, MS PhD, Melissa Title: President
Organization: Technomics Research, LLC
Date: 04/12/2012
Comment:
TECHNOMICS RESEARCH COMMENTARY:
RESPONSE TO CMS’ PROPOSED DECISION MEMORANDUM FOR TENS COVERAGE FOR CHRONIC LOW BACK PAIN

Introduction

CMS proposes to cover TENS for chronic low back pain (CLBP) with conditions of evidence development. The conditions are that the patient be enrolled in a well designed, randomized-control trial (RCT), the primary purpose of which is to test whether TENS improves the health outcomes

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Rappaport, Richard Title: President
Organization: Panther Medical.
Date: 04/12/2012
Comment:
TENS has been prescribed for low back pain since the early 1970 s. It is a safe ,effective, non addictive method of treating chronic pain. Patients become addicted to pain medications. They are expensive. TENS has no side effects and is less costly than medications over the course of treatment. It should not be discontinued.
Blymyer, Wendy Organization: Brookings Chiropractic
Date: 04/12/2012
Comment:
I can't believe you would deny a person with a disease like cancer. Someone with a disease such as cancer would need relief from as much pain as possible.
Sperlich, Chris Title: Sales
Organization: PSS
Date: 04/12/2012
Comment:
[PHI Redacted] If you discontinue the payment for these devices. You will have allowed the patient no choice in their treatment. And no alternative but the physician to prescribe drugs.
Konsin, John Title: President and Chief Executive Officer
Organization: RS Medical
Date: 04/12/2012
Comment:

To CMS VIA EMAIL/Web Posting

Louis Jacques, MD
Tamara Syrek Jensen, JD
James Rollins, MD, MSHA, PhD
Brijet Burton, MPP, MS, PA-C
Rosemarie Hakim, PhD
Susan Miller, MD
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Dear Dr. Jacques, Ms. Jensen, Dr. Rollins, Ms. Burton, Ms Hakim and Dr. Miller:

At your request, this provides comment on your proposed coverage for Transcutaneous

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Fulginiti, James Date: 04/12/2012
Comment:
As a medical provider that uses tens regularly to treat back pain I feel that the loss of this option would be detrimental in the treatment of my patients.
Ward, R. Scott Title: President
Organization: American Physical Therapy Association
Date: 04/12/2012
Comment:

April 12, 2012

Susan Miller, MD
Lead Medical Officer
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Re: National Coverage Analysis (NCA) Proposed Decision Memo for Transcutaneous Electrical Nerve Stimulation for Chronic Low Back Pain (CAG-00429N)

Dear Dr. Miller:

On behalf of our 82,000 member physical therapists, physical therapist assistants, and students of physical

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Cosentino, Joe Date: 04/12/2012
Comment:
[PHI Redacted] I am shocked that it would be a consideration of yours to remove it from a reimbursable option for pain relief. I strongly support the continuation of TENS and the reimbursement of it in the Medicare program. Joe Cosentino
Kathy, Wendlandt Title: Occupational Therapist
Date: 04/12/2012
Comment:

Lower back pain is a barrier to completing and complicance with physical and occupational therapy and completing ADLs.

By restricting the coverage of TENS for patients suffering with chronic low back pain we are taking away a conserviative treatment option that allows participation in therapy, ADLS, work and related tasks. i have heard patients report that they have not used as much medications since they started their tens unit, I have heard pts say they have not increased

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Price, Mike Date: 04/12/2012
Comment:
Since the mid 80's I have monitored the results from patients using TENS. I have had hundreds of patients effectively reduce and in many cases eliminate their pain as a result of TENS in the home setting . TENS provides pain relief while allowing patients to reduce and often eliminate their pain medication. Medicare's current evaluation process requiring the patient to return to the Dr after wearing the unit for 30 days assures that the patient is benefitting from the device. Eliminating

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Viener, Robert Title: Physician Orthopedic Surgeon
Date: 04/12/2012
Comment:
I have used TENS for the treatment of chronic low back pain for more than 15 years. I have found that most of my patients have received substantial benefit from this modality reducing the need for strong narcotics and allowing them to be more active in their lifestyle. I recommend its continued acceptance for treating this condition.
Wood, Dr Michael Title: Owner
Organization: North Florida Chiropractic Center
Date: 04/12/2012
Comment:
TENS…No Side Effects (especially with long term use), Safe on the Body, Non-Addictive, FDA Approved for 30 years, Medicare Approved for 20+ years, Non-Allergenic, and a viable treatment alternative for patients that CANNOT take Prescription Pain Meds.
Kozma, Dr Abe Title: Owner
Organization: Chiropractic and Acupunture Center of Sarasota
Date: 04/12/2012
Comment:
In my opinion, TENS is one of the best long-term treatments for any Chronic Pain issue (including CLBP). TENS has little to no side effects, TENS is not addictive, TENS does not affect other body parts (Liver, Kidney’s, etc) and it’s cost-effective and easy to use. The FDA has approved TENS as a safe and effective treatment for CLBP and other pain ailments for over three decades…restricting this coverage compromises my patient’s welfare by eliminating a very effective and viable treatment

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Wilson, Dr Sabastian Title: Owner
Organization: Healing Hands Chiropractic
Date: 04/12/2012
Comment:
My patients depend on their TENS device to address their long term pain management (especially CLBP). Though the rules prohibit me as a DC from prescribing a TENS to my Medicare patients, I get asked all the time for a TENS device. Why? Patients understand the long term side effects of chronic long term use of prescription medication for pain management. By the same token, they are aware that the long term use of a TENS for their Chronic Pain (CLBP, Sciatica, etc…) will have NO side

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Griffin, Dr Sherri Title: Owner
Organization: Griffin Chiropractic
Date: 04/12/2012
Comment:
Many of my patients are allergic or have allergic reactions to pain medications. Therefore I prescribe and recommend the use of a TENS device for my patients pain maintenance including CLBP. TENS afford my patients the opportunity to lead normal, active lives without having to worry about the long term effects of pain medication. Patients are becoming more educated about what they are putting in and on their bodies…having a healthy, holistic option to address their CLBP is key to their

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Levine, Joel Date: 04/12/2012
Comment:
Please keep continued coverage for TENS. Thank you.
Lane, Dr Tommy Title: Owner
Organization: Lane Family Chiropractic
Date: 04/12/2012
Comment:
It has been my experience as a Physician that TENS devices are very beneficial for patients with CLBP. For many of my older patients (60 yr+), this is the only modality that works as they try to lead an active lifestyle. Additionally, this form of pain management has “ZERO” side-effects when compared to using prescription pain medication. Not having this option would be extremely detrimental to the health and wellness of my patients overall.
Payne-Murphy, Margaret Title: Physical Therapist
Date: 04/12/2012
Comment:
To Whom It May Concern,
I have been a therapist for 33 years and have used TENS throughout the course of my career in numerous settings – in-patient, home care, transitional and extended care and most currently, out-patients. TENS has consistently proven to be of benefit in providing significant pain relief without medication to patients with chronic pain, especially those with chronic low back pain. It is well known that prolonged use of pain medication promotes dependency and results in

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Powelson, Deanna Title: FNP-BC
Organization: SSM Health Care
Date: 04/12/2012
Comment:
I have many patients who are on Medicare who use TENS units for their chronic low back pain. It feel it would be a burden to them to have to sign up for a clinical trial in order to qualify for this device. Many of these patients would opt not to have the device if it meant being a part of a study, and at times this is the only treatment that works for their condition.
Lanford, Keith Date: 04/12/2012
Comment:
My advise would be for Medicare to continue TENS coverage, but do so at a rate that is more in line with market prices. (maybe in the range of about $95, which would be less than a third of what they are covering now)Patients would still get the much needed product and Medicare would save lots of money. Also at the low payment, there is very little incentive for abuse.
Jensen, Kala Title: Graphic Designer
Organization: Medi-Stim, Inc.
Date: 04/12/2012
Comment:
It would be an absolute shame if TENS was not covered by Medicare. Prescription drugs are abused every day, killing more people than heroin and cocaine combined, when there is a SAFE & HEALTHY alternative for pain relief- TENS. Maybe the topic of discussion should be reconsidered here.
Dahl, Amy Date: 04/12/2012
Comment:
I would like to ask that you reconsider discontinuing the coverage of TENS for Chronic Low Back Pain. TENS has provided much needed relief for [PHI Redacted] who had a Low Back Spinal Fusion in July of this year. The TENS has made it possible for her to reduce the number of habit forming narcotics that she takes for pain. TENS has made a difference in her life and allowed her to return to daily activities (walking) which she was unable to do without the TENS due to the pain.
Litke, ATC, LAT, Sara-Ann Title: Athletic Trainer
Date: 04/12/2012
Comment:
Please continue reimbursement for TENS use. I have seen the positive benefits of using TENS for pain management and relief by both athletes and laborers of all ages. Many patients with low back pain and chronic pain have experienced positive results with the use of TENS. This is a great tool that health care providers can prescribe to patients at a low cost for home therapy. It is a safe alternative to prescribing pain medications, and is preferred by individuals who are able to continue

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Schweizer, Scott Date: 04/12/2012
Comment:
This has been a very effective treatment in my patients.
Fitzgerald, Denise Title: Shipping/Receiving Clerk
Organization: Medi-Stim
Date: 04/12/2012
Comment:
There is an obvious need for tens units for lower back pain and it wouuld be a shame to discontinue coverage .
Hareza COf, CFTs, Scott Title: COf, CFTS
Date: 04/12/2012
Comment:
Tens units help lower the the pain level of the user, there for increases activities of Dailey living. I
Vitanzo, Peter Date: 04/12/2012
Comment:
As a practicing physician who sees numerous patients who receive these units I am concerned that available treatments options will be greatly limited if these units are not covered. In many medicare aged patients the treatment options (ie surgery) can be very limited secondary to medical comorbities and limitation on narcotic/pain medication use (ie side effects. For many, these TENS units are the only option they have to achieve some pain relief.
Grollman, Larry Date: 04/12/2012
Comment:
I am a certified athletic trainer with 32 years of experience. During that time, I have worked with many patients while under the supervision of a physician, who have used TENS as a useful modality for low back pain. Many of these patients have had positive responses to this low-cost tool without the negative side effects and addiction risks of medications, especially high risk opiods. In addition, TENS is easy to use and convenient for patients to use at home. Most importantly, most of my

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Murdoch, Tim Date: 04/12/2012
Comment:
With the patients that I see we have noticed great success in limiting pain meds by using TENS Therapy. TENS Devices work extremely well with controlling pain.
Marino D.O., Lisa Date: 04/12/2012
Comment:
Please do not restrict tens unit coverage for my Medicare patients. Most of my patients who are on Medicare are unable to take narcotics or any other oral medication for pain, the tens unit allows them to gain relief without ingesting medication
Esteban, Ron Title: Directof of Ancillary Services
Organization: Orlando Orthopaedic Center
Date: 04/12/2012
Comment:

I'm commenting on the possibility of MC eliminating Trancutaneous Electrical Nerve Stimulation as a covered code.

As a large orthopaedic practice that treats thousands of patients each year, we frequently use TENS units as an alternative to costly medications and epidural injections. The positive feedback and clinical results we've received from patients has been excellent, and we often hear from patients how they would be unable to do their normal, daily tasks without the use of

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Bush, Julie Date: 04/12/2012
Comment:
Tens has been a useful modality for our patients with chronic painn specificallly back pain. A lot of our patients have responded well to this low cost pain management tool. It has reduced the amount of pain medication that the patient requires. There are very few if any negative side effects. Please consider keeping this as a benefit for medicare patients. Thank you
Steward, Elizabeth Date: 04/12/2012
Comment:
To Whom It May Concern: TENS has been a great relief to [PHI Redacted], my elderly family members, friends and neighbors I have recommended it too. Please do not romove the coverage. It's a refreshing alternative to popping pills. Thank you, Elizabeth Steward
Bird, Michelle Date: 04/11/2012
Comment:

I have only been in the Rehab industry for a year or so, but in that time, I have seen the positive effects of TENS therapy in the lives of patients with chronic back pain.

One of my primary responsibilities is to be the primary contact person at our company for patients who need to re-order supplies inorder to continue to use their TENS units. So when patients call our company to request more electrodes, I get to speak to them. I am always pleasantly surprised at how often these

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pelechaty, orest Title: Director
Organization: Integrated Holistic Medicine
Date: 04/11/2012
Comment:

TENS for lumbalgia has been a safe and cost effective way to help many of my patients with chronic pain. Removing this treatment option will increase costs and increase dangerous side effects from drugs, further escalating human suffering and overtaxing the system to everyone's detriment. Cover the treatment!

Dr. O. Pelechaty
Bocchino, Carmella Title: EVP, Clinical Affairs and Strategic Planning
Organization: America's Health Insurance Plans (AHIP)
Date: 04/11/2012
Comment:

April 12, 2012

Louis Jacques, MD
Director, Coverage and Analysis Group
Centers for Medicare and Medicaid Services
Mail Stop C1-09-06
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Dear Dr. Jacques:

Thank you for the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s) Proposed Decision Memo for Transcutaneous Electrical Nerve Stimulation for Chronic Low Back Pain (CAG-00429N).

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Boyd, Jim Date: 04/11/2012
Comment:

I am a retired massage therapist and myofascial release specialist with 14 years of experience treating people who suffered from chronic low back pain. I am licensed by the state of Alabama and was nationally certified by NCTMB before my retirement. I had the opportunity to treat many patients who combined my therapies with transcutaneous electrical stimulation from other health providers. Patients who combined the therapies recovered and returned to normal life functions in much greater

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Goff PT Cert MDT, Nathan Organization: Ogden Clinic Physical Therapy
Date: 04/11/2012
Comment:

As a Physical Therapist working in the field for over 18 years, I wanted to take a moment to voice my concern about the proposal to discontinue TENS as a source for treatment for Chronic LBP. Contrary to what some believe, that everyone benefits from a TENS treatment, I have taken a more pragmatic approach to my use of the modality in my practice. I believe that exercise is the most beneficial way to treat both acute and chronic back issues. With that being said, There are volumes of

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Lynch, Ann-Marie Title: Executive Vice President, Payment and Health Care
Organization: The Advanced Medical Technology Association
Date: 04/11/2012
Comment:

April 12, 2012

Louis B. Jacques, MD
Director, Coverage & Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop C 1-09-06
7500 Security Blvd
Baltimore MD 21244

RE: Proposed Medicare Coverage Decision Memorandum for Transcutaneous Electrical Nerve Stimulation (TENS) for Chronic Low Back Pain (CAG-00429N)

Dear Dr. Jacques:

The Advanced Medical

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Meadows, PT, DPT, Aiyana Organization: EPT Rehabilitation
Date: 04/11/2012
Comment:

Dear CMS,

I am writing to express my support for continuing the existing coverage of transcutaneous electrical nerve stimulation (TENS) for patients with chronic lower back pain.

I have been a Physical Therapist for 4 years. I have found TENS units to be extremely effective in treating chronic lower back pain especially in patients who continue to use TENS units on a regular basis. Due to chronic nature of patient's lower back issues, many of them continue to have

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Sammis, Glenn Title: Licensed Professional Counselor
Date: 04/11/2012
Comment:
[PHI Redacted] The revision to to reduce or elimiante the coverage for the TENS unit SHOULD NOT BE ENACTED! It will be costly to the government. It eliminates access to care that has been proven effective and is less costly than medication that would be substituted for pain control. It further interfers with the ability of the doctors ability to provide effective care.
ORR, STEVE Date: 04/11/2012
Comment:

Dear Sir,
I have been a licensed massage therapist for more than 20 years and the TENS is definitely a great pain relieving, drug free tool for lower back pain.

I heartliy ask to you reconsider your faulty policy to drop the TENS from Medicare coverage. As a part of the golden aging baby boomers, we and our socity in general are way to dependent on drugs for a multitude of conditions. Please continue to keep this drug-free method of pain control covered by Medicare...if

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May, Nancy Title: Mrs.
Date: 04/11/2012
Comment:
[PHI Redacted] I thank the Lord that he has allowed technology to come a long way since the days when [PHI Redacted] was diagnosed with arthritis at the age of 23. She had 3 young children (one was a newborn). She was in so much pain that she tried everything known to man to feel better, including surgery to place steel balls in her hip joints. She coded on the operating table, they lost her for a while, but were able to bring her back. The doctor stopped the

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GUPTON, HENRY Title: MD
Date: 04/11/2012
Comment:
There are too many patients in need of these devices to manage their pain.
Camuso, Gail Date: 04/11/2012
Comment:

I think it's horrible for Medicare to even consider abolishing coverage for any tens unit or its accessories for several reasons.

[PHI Redacted] Using the machine is both cost-effective & non-addictive. Medicare does not even pay for any medications so why would they also take the tens & electrode pads & batteries away from us. It sounds like Medicare would rather have us pay for expensive pain killer drugs that make you so sleepy & nonproductive.

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Elias,ND, John Title: ND
Organization: Natural Wellness
Date: 04/11/2012
Comment:

* Useful modality for pain management
Tens units are a safe alternative to medications They have ben in use for decades - low cost and effective. Removal of coverage will drive more pain patients to high risk and more expensive and habit forming opioids.
Tens units are useful in-home means of pain relief and management
There is no risk of overdose - very low incidence of negative side effects.

Bottom line - Drug companies do not like the competition.
Spradling, Lisa Title: Vice President
Organization: S&S Medical Supply
Date: 04/11/2012
Comment:
I am so diappointed that Medicare would take away a non-evasive pain management tool like this. So many people are addicted to pain meds and they want more? This is a proven pain management tool.
Galvez, Lisa Date: 04/11/2012
Comment:
I have been a Physical Therapist since 1992. It is in my experience that using TENS is an safe effective way to treat CLBP patients especially those patients who coninue to use TENS for pain relief beyond 90 days. My practice depends on the continued existing coverage of TENS for treating my patients suffering from CLBP especially with how little therapy sessions insuracne companies approve these days. Adoption of the TENS NCD by CMS wkould be severe and potentially irrevocable.
Long, Charles Date: 04/11/2012
Comment:
I am against the revision to the existing National Coverage Decision for the TENS unit. [PHI Redacted] The government should not interfere with physicians ability to offer alternatives in care.
Ferrance, PT Date: 04/11/2012
Comment:
TENS treatment is an important part of pain management. To remove it from the list of tools that practitioners have to help mitigate pain means that there will be more people seeking/using pain medications which could mean more addiction to pain medications... something we already have too much of.
PT Ferrance
Schwartz, Steven Title: N/A
Organization: N/A
Date: 04/11/2012
Comment:
The revision should not be enacted for many reasons. Fisrt, doctors, not government should decide whether TENS is a viable option for a patient. Second, it's a physician proven and tested method of pain treatment. Thirdly, enacting this proposal would lead to more dependence on expensive, addictive narcotics with numerous negative side effects. Fouthly, the clinical trials involved in the proposal are way to costly and time consuming. Finally, the proposal focuses solely on treatment and

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Ditmars, Jr., DPM, John Date: 04/11/2012
Comment:
It is important to be able to help chronic nerve pain patients, especially Diabetic Neuropathy patients, with the use of TENS unit therapy. Many cases the only time they get relief from their neuropathy pain is when they have their TENS unit applied. This is much better than having to use pain medication. Please don't stop the ability for doctors to use TENS units in their practice. Thanks, Dr. Ditmars
Jasper, Sheri Date: 04/11/2012
Comment:
TENS is a good alternative to expensive drug options for pain relief in chronic or acute pain conditions. This is a valuable treatment for Medicare patients to have access to.
Drzewiecki, Linda Date: 04/11/2012
Comment:
After speaking to numerous patients who currently use the TENS unit, the reduction in chronic pain among them is quite noteable.The satisfaction rate for this unit is tremendous!! Instead of harsh and addictive opioids, this unit is a safe and effective way of treating pain. Current pain medications that are used are highly addictive, and very unsafe to patients mental health. The drugs can cause unneccesary side effects that can affect a persons inability to function normally. The TENS unit

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Campbell, Laurna Title: Customer Relations
Organization: Patient's Choice
Date: 04/11/2012
Comment:
While conducting surveys with patients using the TENS, I have been told of their success with treating their chronic lower back pain. They report relief that allows them to move more freely. The portability allows them to leave their homes for outings for longer periods of time than they have previously experienced. Many have been able to reduce the amount and/or frequency of pain medication. Use of the TENS does not produce the unwelcome side effects that come with the use of drugs. The

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Annino, Lauren Title: CEO/President
Organization: The Freedom Walker Co.
Date: 04/11/2012
Comment:

I have literallly treated thousands of elderly people with low back pain through e stim/TENS . For the past 15 years my practice has helped people decrease opiates, narcotics and anti inflammatory use. The 2008 published randomized meta analysis which was in journal of pain gave a 7 out of 10 reduction in pain for lower back pain. This has been the only hope for peopple that want a portable non addictive way to treat pain and decrease physical therapy costs and pharmaceutical use. Why not

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Morton, Cynthia Title: Executive Vice President
Organization: National Association for the Support of Long Term Care
Date: 04/11/2012
Comment:

April 11, 2012

Louis B. Jacques, MD
Director, Coverage & Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare & Medicaid Services
Mailstop C1-09-06
7500 Security Blvd
Baltimore MD 21244

RE: Proposed Medicare Coverage Decision Memorandum for Transcutaneous Electrical Nerve Stimulation (TENS) for Chronic Low Back Pain (CAG-00429N)

Dear Dr. Jacques:

The National Association for the Support of Long Term Care (NASL)

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PREBE, LUCY Title: SHIPPING SUPERVISOR
Date: 04/11/2012
Comment:
I FEEL MEDICARE SHOULD RECONSIDER COVERAGE FOR THE USE OF TENS UNITS FOR CHRONIC LOW BACK PAIN. I DO FEEL THAT THE TENS UNITS DO HELP LOWER BACK PAIN AND IT WOULD BE A SHAME IF PEOPLE HAD TO DEAL WITH THE PAIN DUE TO THE FACT THAT THEY COULD NOT GET COVERAGE FOR THE UNITS.
Uminski, Maria Date: 04/11/2012
Comment:
It would be a grave mistake to deny coverage of a well documented, long proven therapy to address chronic pain. TENS therapy is an excellent alternative to the use of pain medications. Not only is it more cost effective than medications, it does not have the side effects of narcotics....for example, lethargy, nausea, addiction, stomach upset. the list goes on. I urge CMS to continue coverage of electrotherapy.
Pulliam, John Title: Physician / Neurosurgery
Date: 04/11/2012
Comment:

Sent: Tuesday, April 10, 2012 12:23 PM
To: CMS CAGInquiries
Subject: Proposed Decision Memorandum for Transcutaneous Electric Nerve Stimulation for Chronic Low Back Pain (CAG-00429N)

To whom it may concern:
I have been informed about CMS’s intention to discontinue coverage of TENS units for the treatment of chronic low back pain. I find this to be quite absurd, as this is often one of the only non-invasive forms of treatment that is beneficial in the treatment of this

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Jenkins, Katherine J. Date: 04/11/2012
Comment:
I truly do understand all this about clinical trials after 90 days use of an electrical stimulator. [PHI Redacted] To me this seems like Medicare wants to limit or eliminate access to medical care that has been approved by the FDA as safe & effective for Chronic Low Back Pain as well as other areas of the body for at leaset 30 years and (I'm told) been covered under Medicare for 20 years as well. To me this just seems like another way to spend "More" money than to actually

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Palermo, Francis Date: 04/11/2012
Comment:
I am a practicing physician and am a member for the AAN as well as the AAPM&R. I occasionally prescribe TENS for low back pain - chronic or acute. I have been frustrated with the speed at which patients become dependent on narcotics, and the lack of transition off of them. Some of my patients stay on the same dose of long acting narcotics and use TENS just to tolerate increased activty.
I appreciate your hope that "using TENS patients will require a lower amount of medications . . ."

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Murrow, Linda Date: 04/11/2012
Comment:
Because of the FDA approval of the TENS machine for Chronic Back Pain I am asking that the use of this machine continue to be extended beyond 90 days. Chronic back pain does not go away. TENS helps to keep some patients off of pain medicine that can become habititual thus making TENS an alternative treatment. I am opposed to government telling doctors what is best for their patiens. If you tell patients that they can use it for only 90 days then medicare would still be paying for treatments

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LA ROCQUE, GERALYN Title: Accountant
Organization: Medi-Stim INc
Date: 04/11/2012
Comment:
I believe that TENS units definitely assistance in alleviating lower back pain. One of my acquaintances has used a TENS unit for the past five years because she has lower back pain. But, the units are used for other pain as well. This is a simpler more effective way of alleviating pain compared to the "norm" of filling people with drugs that numb and make people "dumb" to the world around them. Use TENS and eliminate the drugs!
ENGSTRAND, SARAH Title: OFFICE MANAGER
Organization: MEDI-STIM, INC.
Date: 04/11/2012
Comment:
TENS for low back pain is useful to many. I have been working in this industry for 10 years now and have heard many wonderful comments made on how TENS has helped patients with low back pain. To take this away and have them rely heavier on prescription medications, would just not be the correct answer. Just as though not every drug works for everyone, why would TENS be just discontinued for those it DOES work for.
Hentosh, David Date: 04/11/2012
Comment:
[PHI Redacted] I strongly object to the proposed Medicaid and Medicare Services proposed revision of the existing National Coverage Decision which would limit to coverage for treatment of low back pain. The government has no business making medical decisions that can only best serve patients by medical professionals. This would indeed be another way for the government to interfere and micro-manage the lives of Americans that it has not business doing which would also open the

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Sand, Marilyn Date: 04/11/2012
Comment:
PLEASE do not change this coverage of TENS units [PHI Redacted] has had a TENS units since 2008 and relays on it every day. Would not function with out it.
Landry, Charles Title: DO
Organization: Manchester Osteopathic Healthcare
Date: 04/11/2012
Comment:
This decreases the utilization of central nervous system pressing pharmaceuticals and is a safe alternitive for our Medicare beneficiaries and should not be removed from coverage.
Roberts, Alisa Title: DO
Organization: Manchester Osteopathic Healthcare
Date: 04/11/2012
Comment:
This decreases the utilization of central nervous system pressing pharmaceuticals and is a safe alternitive for our Medicare beneficiaries and should not be removed from coverage.
Jorgensen, Douglas Title: DO
Organization: Manchester Osteopathic Healthcare
Date: 04/11/2012
Comment:
This decreases the utilization of central nervous system pressing pharmaceuticals and is a safe alternitive for our Medicare beneficiaries and should not be removed from coverage.
Hinderer, Seven Title: MA
Organization: PHYSICAL MEDICINE & REHAB
Date: 04/11/2012
Comment:
ELECTRICAL NERVE STIMULATINO FOR CHRONIC LOW BACK PAIN HAS BEEN A GREAT SORCE FOR HELPING PATIENTS WITH THIS KIND OF PAIN NOT TO MENTION HOW MANY PATIENTS THERE ARE YOU ARE TALKING ABOUT A LOT OF PEOPLE NOW LIVING WELL INTO THE OLDER AGE NOW AND I THINK THEY BELIEVE THEY SHOULD BE ALOWED TO BE AS PAIN FREE AS WE CAN MAKE THEM IF THIS HELPS THEM WHO ARE YOU TO TAKE THIS AWAY FROM THEM IAM SURE IF THIS WAS YOU IT MIGHT BE A DIFFERENT STORY.
Gray, Steve Date: 04/11/2012
Comment:
Our patients generally find TENS units to be very helpfull as part of their treatment for chronic back pain. It is safe and cost effective.
Billig, B. Date: 04/11/2012
Comment:
Do not limit non-toxic, non-addictive options for treatment of Chronic Low Back Pain. One area of ailment limit/restrictions will lead to other ailment restrictions/cutbacks for this form of treatment/therapy.
Saltzburg, Michael Date: 04/11/2012
Comment:

I have been in practice as an orthopedic surgeon for over thirty years. In my experience, TENS effectively treats CLBP patients, especially those patients who continue to use TENS for pain relief beyond 90 days.

My practice depends on continued existing coverage of TENS for treating my patients because it reduces the number of tertiary orthopedic referrals for cervical and lumbar arthrodesis (fusion).

For these reasons, the CMS should continue to allow coverage of TENS

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Hunt, Mark Title: Staff Physical Therapist
Organization: John Muir Health
Date: 04/11/2012
Comment:
To Whom it May Concern, I am writing to express my disapproval of the proposal to eliminate existing coverage of TENS for chronic low back pain after 90-days. For many of my patients, this is a crucial cost saving means of managing their back pain. Rather than expensive prescription drugs, epidural injections, medical appointments with orthopedists, neurologists, pain management specialists, physical therapists, etc, they can manage their pain ON THEIR OWN, AT HOME. With the emphasis on

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Dawidczyk, Trish Title: Senior Reimbursement Specialist
Organization: Covidien
Date: 04/10/2012
Comment:

April 6, 2012

Louis B. Jacques, MD
Director, Coverage & Analysis Group
Office of Clinical Standards and Quality
Centers for Medicare &Medicaid Services
Mail Stop C1-09-06
7500 Security Boulevard
Baltimore, MD 21244

RE: Proposed Medicare Coverage Decision Memorandum for Transcutaneous Electrical Nerve Stimulation for Chronic Low Back Pain (CAG-00429N)

Dear Dr. Jacques,

I am writing to you on behalf

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Flagg, D.C., Malissa Date: 04/10/2012
Comment:

To Whom It May Concern,

I am a chiropractor at the Back Pain Relief Clinic in Jackson, TN. I am writing this email with concerns about the proposal to eliminate existing coverage for transcutaneous electrical nerve stimulation(TENS). I have been using TENS units in patient care for over a year and I have found that patients find it very helpful for managing chronic low back pain. Most of these patients have tried various medications that have not been helpful for elimination of

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Mayo FNP, BC, Christina Date: 04/10/2012
Comment:

I am a Nurse Practitioner at PARS Pain Center at 1212 Garfield Ave St 202 in Parkersburg WV 26101. My phone number is 304-865-7277. Fax is 304-865-7272. I am writing due to the proposal to eliminate existing coverage of a TENS unit. I have personally seen the benefits and improvement in the quality of life that patients experience while using a TENS unit. Without weakness they would not qualify for a muscle stimulator but could still benefit from a tens unit. Please consider this while

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Davis MD, Dr. Glenn Title: Physician, Lecturer, Author
Organization: Laurel Highlands Patient Education and Pain Care Center
Date: 04/10/2012
Comment:
Medical Pain Management: This proposal will not save money, it will further increase the reliance of Medicare beneficiaries on medications which can be devastatingly expensive. Many of these patients are not candidates for surgery, which is best avoided for pain only. Implanted neurostimulators and intrathecal pumps being pushed by anesthesiology pain management are also horrendously expensive, not entirely reliable, have a short life, higher than published complication rates, require

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Murinchack, Brandy Date: 04/10/2012
Comment:
Good evening, I am writing to address this very important issue regarding the use and effectiveness of the TENS unit for treating Low back pain. As a field representative for a dme company I have seen and treated thousands of patients with this diagnosis for the past 14 years. I believe the TENS unit provides substantial relief for chronic low back pain no matter the ideology. Patients have reported not only pain reduction, improved mobility and endurance but also greater function with

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Shaw, Jerod Title: M.D. (physician)
Organization: Hill Country Pain Associates
Date: 04/10/2012
Comment:

To whom it may concern,

I am a pain physician in Texas. Given all of the problems with narcotic abuse and the risks associated with chronic narcotic therapy, I use a TENS as an extremely safe alternative for management of chronic pain. I would rather my patient use a TENS unit than hydrocodone or oxycodone for managment of his or her chronic pain condition. I have found TENS therapy, on many occasions, to be a highly effective treatment for chronic myofascial pain. I truly

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Baker, Thomas Title: president
Organization: Tennessee Physical Medicine and Pain Management
Date: 04/10/2012
Comment:

I am a physical medicine and rehabilitation physician and have a busy pain management practice in Tennessee. We have a significant problem with opioids nationally and locally in Tennessee. I have used TENS treatments in most of my chronic low back pain patients as an avenue to treat their pain safely and effectively. Outcome measures for research purposes for any physical treatments (including TENS)in patients with chronic pain is very difficult and therefore has limited research bases

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Graves, Scott Title: PRESIDENT
Organization: GOLDEN STATE MEDICAL, INC.
Date: 04/10/2012
Comment:

April 10, 2012

To Whom It May Concern,

As President of Golden State Medical, Inc., I am writing you to discuss our company’s data with regard to TENS Units (E0730) and the supplies (A4595), and to ask that you reconsider your proposal to stop reimbursement for these products (Proposed Decision Memorandum for Transcutaneous Electrical Nerve Stimulation for Chronic Low Back Pain (CAG-00429N)).

Golden State Medical, Inc began in 1991 in Auburn California. Our

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Schaub, Donna Date: 04/10/2012
Comment:
CMS should not change the existing coverage of TENS units. The 90 day is not a medical assesment and certainly the trails would be costly and not benefit anyone.
Mears, Rose Date: 04/10/2012
Comment:
[PHI Redacted] I feel there are too many people taking pain killers that cause serious family and health problems. Do not stop doctors from prescribing TENS machines to help treat back pain or arm and leg pain.
Everett, Gina Date: 04/10/2012
Comment:
[PHI Redacted] To disallow this therapeutic benefit would ultimately increase costs for most patients.
Marascso, Erica Date: 04/10/2012
Comment:
Transcutaneous Electrical Nerve Stimulators (TENS) are used for the symphtomatic relief and management of chronic (long-term) intractable pain and as an adjunctive treatment in the management of post- surgical and post-traumatic acute pain problems.I have worked with numerous patients that suffer with CHRONIC back pain, and the use of the TENS units changes the quality of their life. Many people are intolerable to oral medication or can’t take it in order to function in their daily life. Other

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oleniacz, jonna Title: PA-C
Organization: Workstar Injury Recovery Center
Date: 04/10/2012
Comment:

Greetings,

I am a physician assistant in an injury recovery center. It came to my attention last week that there is a proposal to stop covering these much needed units. More often than not, my chronic low back pain sufferers benefit from the use of TENS units. Having a home unit is a safe, effective and comparatively inexpensive way to help manage their pain. When the physical therapy ends and the patients are discharged to a home program, this is one of the most effective

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Sykes, Brian Date: 04/10/2012
Comment:

To Whom It May Concern:

As a Chiropractic Physician in the state of Tennessee I am opposed to the action of restricting the usage of TENS for chronic lumbalgia patients. This device has proven to be a safe, effective treatment for patients in our office. Some of our patients have tried other treatments such as medication and even spinal injections with less success. With minimal contraindications this device is safer for patients than most treatments. It does the patient a

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Ruff, Bill Title: CEO
Organization: Vector Rehabilitation, Inc.
Date: 04/10/2012
Comment:

To whom it may concern,

I am writing on behalf of my physical therapists at Vector Rehabilitation, Inc. regarding CMS proposal to eliminate existing coverage for transcutaneous electrical nerve stimulation (TENS) for chronic lower back pain. We are a non profit 501 (C) (3) free standing outpatient physical therapy clinic, treating many Medicare beneficiaries. A large percentage of those patients, come to us with chronic back pain and even after utilization of manual therapy and

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Humphry, J Date: 04/10/2012
Comment:

National Coverage Analysis (NCA) Tracking Sheet for Transcutaneous Electrical Nerve Stimulation for Chronic Low Back Pain (CAG-00429N)

As a recent reitired medical director for BCBS Hawaii, I have been dealing with the TENS question for years. A quick check of the Internet shows a number of TENS units available for less than $100 dollars and some as low as $34. The TENS cost considerably less than an office visit or the co-payment for chronic medication.
First, if there is a

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Castille, J Date: 04/10/2012
Comment:
I have tried TENS and it has not worked for me. It feels like I'm being tortured. There is nothing comfortable about it.
K, Nancy Date: 04/10/2012
Comment:
Regarding TENS Units and benefits thereof. I had two occasions to have treatment with this unit. I had sciatic lower back pain. I experienced relief and it lasted months after the treatment.
Scott, John A. Title: Architect
Organization: Self-Employed
Date: 04/10/2012
Comment:
I read the "Proposed Decision Memo for Transcutaneous Electrical Nerve STimulation for Chronic Low Back Pain (CAG-00429N)" and while i know CMS needs justification for action, this proposal is (in my opinion) an absurd, travesty of extended verbage that is an unbelievable waste of money. time and effort to try to save "Money"!!
What happened to "COMMON SENSE"????
Nester, Mary Date: 04/10/2012
Comment:
Iam shocked that the gov't is attempting to interfere with treatment alternatives other than drugs.Restricting the use of the TENS machine will greatly impair patients who are currently getting some relief;it would increase costs to Medicare for drug use,and the side effects these drugs often present.A randomized clinical trial is useless at this point;we already know that the TENS is safe, effective,and has been used for over 20 yrs.It is used in REHAB clinics throughout the US and in

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Thomas, Ty Title: Medical Doctor
Organization: Alabama Pain Physicians
Date: 04/10/2012
Comment:
It is valuable for the patient to try the TENS unit before deciding to keep it. TENS units are valuable because they offer a tool for long term pain management for relatively low cost compared to other durable medical equipment. Many of my patients have benefited from the use of a TENS unit.
Thoma, R. Brian Title: Medical Doctor
Organization: Alabama Pain Physicians
Date: 04/10/2012
Comment:
TENS units are valuable because they offer a tool for long term pain management for relatively low cost compared to other durable medical equipment. Many of my patients have benefited from the use of a TENS unit. In addition, it is valuable for the patient to try the TENS unit before deciding to keep it.
Alvarez, Erick Title: Physical Therapist
Organization: Nebraska Spine Center
Date: 04/10/2012
Comment:
As a physical therapist, I have found TENS to be an effective tool for pain managment of chronic low back pain in particularly when Pain medicine has been ineffective for treatment or due to side effects from other medications that the patient is taking. Overall, I have patients express gratitude and improvement in function of activities of daily living while utilizing TENS unit.
Afghani, Philip Date: 04/10/2012
Comment:
I would like to speak on behalf of the benefits of using TENS for treatment. We have seen numerous patients in many situations, in which they suffer from chronic low back pain for many different reasons, yet all were pleased with the results they received from using TENS. It helped to decreased pain medication dependency, increase motion, and improve the quality of life in many chronic low back patients. I feel this should continue to be a covered service by Medicare for the simple fact it

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Bera, Sylvia Date: 04/10/2012
Comment:
[PHI Redacted] I would like to have this continued to be covered by Medicare.

This comment was submitted within the comment period but not posted until June 18, 2012 due to technical difficulties.

Brutofsky, Anna Date: 04/10/2012
Comment:
I don't think I should be denied access to care for chronic low back pain that has been approved by the FDA, considered safe and covered by Medicare for over 20 years

This comment was submitted within the comment period but not posted until June 18, 2012 due to technical difficulties.

Fox, Denise Title: Mrs. Denise Fox
Date: 04/10/2012
Comment:
I feel that the TENS Unit should be covered by Medicare, to aid in pain relief. [PHI Redacted]

This comment was submitted within the comment period but not posted until June 18, 2012 due to technical difficulties.

Wells, Sandra Title: Mrs.
Organization: none
Date: 04/09/2012
Comment:
[PHI Redacted] My understanding is that is an attempt being made to only allow coverage for the use of a tens unit past 90 days only if patients are enrolled in a randomized clinical trial for chronic low back pain. I certainly have to question the logic in this recommendation. I would beg the CMS to reconsider this change. [PHI Redacted] It would be an injustice to discontinue coverage of its use. Please reconsider and continue to cover this cost. The cost of

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Hollett, Dr Bob Title: Managing Physician
Organization: ExpertHealthDoc.com
Date: 04/09/2012
Comment:
TENS is a viable tool to reduce pain for chronic low back conditions. Removing this tool will cause more physical therapy work to be performed which will cost more money.
Dr Bob Hollett.
Dundas, Stephen Date: 04/09/2012
Comment:

TENS is one of the most useful tools available for treatment of chronic pain, especially back pain. Its reusable and free of side effects. One unit will last for YEARS and once established, requires little or no physician supervision for continued benefit.

I cannot see any point in eliminating TENS as a benefit, as that would adversely impact patient care and unnecessarily increase reliance on pharmaceuticals to treat the pain. Increased pharmaceutical use increases risk of

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Munir, Muhammad Date: 04/09/2012
Comment:
TENS unit in selected population helps with pain, avoid use of addicting narcotics and helps avoid more invasive treatments such as injections and surgery. It also provide a physical way of pain relief and avoid taking more inavasive treatments. Instead of monitoring who prescribes and who gets prescribed a general ruling in preventing medicare beneficiary seems illogical and probably will hurt more patients then helping. Please reconsider this.
Tang, Xuong Title: physician
Date: 04/09/2012
Comment:

Please continue the coverage for TENs unit use for chronic low back pain. It is still a great adjuvant to treating pain. It is a good alternative for patients who cannot take opioid medications; also it can help prevent narcotic dependence.

Eliminating coverage will take away another "tool" for physicians that treat chronic pain.

Again, please allow continue coverage for TENs unit use for patients with chronic low back pain.

Thank you.

Corrigan, Dan Title: COF
Organization: Corr Medical Solutions Inc.
Date: 04/09/2012
Comment:

I have worked with back pain patients for over 7 years.

In that time, I have seen patients who are on suicide watch because their chronic pain was so bad that no pharmaceutical (including injections) would help. I have seen these same patients respond quickly and positively to prescription strength TENS therapy. These severe-pain patients credit their TENS unit with either saving their lives or seriously increasing the quality of their lives.

I have seen over 500

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Balter, Kevin Title: TENS for Chronic Low Back Pain
Date: 04/09/2012
Comment:

As a regular prescriber of TENS who treats patients with chronic pain including chronic low back pain (CLBP) beyond 90 days that benefits from this technology, I am writing this letter in an effort to help ensure continued coverage of TENS and to stop CMS from adopting the proposed National Coverage Decision (NCD) that would restrict existing TENS coverage for CLBP patients.

I am asking that CMS refrain from taking rash, unwise and uninformed action to eliminate this

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kahn, lawrence Title: chiropractic physcian and owner
Organization: west end chiropractic center
Date: 04/09/2012
Comment:
I have been a practicing physician for twenty five years. I have been using TENS with my CLBP patients for this period of time. I find that it has been one of the few treatments that have actually been beneficial for these patients. It would be a shame to not allow these patients to receive this treatment anymore. I implore you to not take away this treatment and please continue to allow me to prescribe TENS therapy to my patients. Lawrence Kahn D.C. N.D.
Grisales, Dario Title: MD
Organization: Pan American Pain Institute PL
Date: 04/09/2012
Comment:
I am a fellowship trained pain management physician with background in anesthesiology. I have practiced for 11-12 years as a pain physician. I have treated numerous patients with TENs units. I always recommend a one month trial, which ensures an adequate time to try on the device and almost all and well above 90% of the patients end up getting the unit because they show the benefits. It is useful to count on another tool to treat pain and not rely only on other procedures or medication alone.

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Hayes, Sean Title: Doctor of Chiropractic
Organization: Hayes Chiropractic
Date: 04/09/2012
Comment:

It has been my professional experience that the use of TENS to treat chronic lower back pain patients has been of tremendous help in the reduction of pain, especially those suffering beyond 90 days.

My practice depends upon this modality and the continuing coverage for treating those suffering from chronic lower back pain. With the raising costs of health insurance copays and deductibles, further burdening the patients with an additional out of pocket cost associated with it not

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Walden, Mark Title: Owner/president
Organization: Walden Chiropractic, PSC
Date: 04/09/2012
Comment:
I have treated back pain for over twenty years as a chiropractor. One of the best things I can give my patients for management of pain between visits is a TENS unit (for acute AND chronic pain). Please continue to reimburse for these units that I give to my patients so that they may be able to continue with their own home treatment of pain . Thanks for your consideration and cooperation with this matter.
Hall, Teresa Title: Occupational Therapist
Organization: Meridian Health Group
Date: 04/09/2012
Comment:
I have been working with individuals who have chronic pain since 1996. One of the best pain control techniques I can give a client is a TENS unit. By using the unit the clients are able to do more in home and out in the community. I would say tht 98% of my clients get benefit. I see all sorts of cdiagnosis from neck pain, low back pain, fibromyalgia, knee pain, hip pain, shoulder pain, piriformis syndrom. Even if the pain was initially brought on by a medical issue that has been resolved,

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Moran, Dr. William Title: Chiropractic Physician
Organization: FCA
Date: 04/09/2012
Comment:
It is my professional opinion that the TENS unit is very effective in helping patients with chronic low back pain. The TENS unit has no side effects and is much safer than having patients on Rx Drugs or NSAIDS. It allows patients to have the ability to do treatment at home, reducing additional Dr. visits.
Rajchgot, Danny Title: Chiropractor
Organization: RAJD Chiropractic Center P.A.
Date: 04/09/2012
Comment:
I am a chiropractor in south florida for over 15 years. I have been using the TENS unit for many years and this has afforded my patients relief from the chronic low back pains, as well as allowed me to work on those regions when the pain was controlled. I believe having the TENS units available for my patients in the future would represent a cost affective approach of managing back pain, treating back pain and of course avoidances of NSAIDS where ever possible
henry, kevin Title: medical doctor
Organization: illinois regional pain institute
Date: 04/09/2012
Comment:
I Find tha the new proposed elimination to access with regards to transcutaneous electrical stimulation very concerning. Any treatment that decreases or eliminates the need for prescription drugs is favorable especially in the elderly population. In the long run this will prove to be a cost savings and decrease the risk of the potentially devestating risks of long term NSAID therapy and the cognative risks and fall risks associated with narcotics and muscle relaxants. I believe that

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derasari, manjul Title: Professional Pain Management
Date: 04/09/2012
Comment:
I am a strong support of TENS
it does help patients with chronic pain without drugs ,
It is selected as a modality ONLY after a successful trial of TENS for one month.
So this eliminates most of the false positives.
Bansal, Pratibha Title: Medical Director
Organization: Pain Rehab of WNY
Date: 04/09/2012
Comment:
I have worked with and recommend TENS units as an alternative treatment method for over a decade. I strongly recommend this product to many as I have seen it work with my patients. I have seen many patients whom have struggled with opioid abuse and are unable to take certain medications, therefore I have prescribed the TENS unit for CLBP. The relief I see in pain management and ROM- with a patient with a TENS unit compared to a patient who does not have a TENS is significant.
Miller, Sara Title: PT
Date: 04/09/2012
Comment:

I'm not sure I understand the logic here and urge you to reconsider. Firstly the criteria for coverage is VERY strict already. It is a 30 day trial period and after that a survey must be complete to show it is working and for medicare to continue payment. Can I ask what doctor would keep prescribing if it is not working?????

Not only that reimbursement is very small. It is a relativley cheap item that has no negative side effects and works great for many.

I'm a pt and

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Yurick, Patti Date: 04/09/2012
Comment:
[PHI Redacted] Additionally, as a Licensed Massage Therapist working in the clinics of multiple Chiropractors during the late 1980's and 90's, I can attest that I witnessed many patients using the TENs units who said they got relief from low back pain from using the TENs units.
McCracken, James Title: Physical Therapist.
Date: 04/09/2012
Comment:
TENS has been in use for many years and there is anecdotal and some empirical evidence of its benefit. I disagree with the determination that it will only be covered if the patient is part of a clinical study at this time. TENS should be covered while studies are being conducted. Then, when the studies are completed a determination of coverage can be made.
Bob, Dr. Date: 04/08/2012
Comment:

TENS is a valuable tool for treatment of chronic low back conditions. If TENS is removed as a tool to treat long term chronic back conditions, more physical therapy will be used in its place which will cost more money.

Thanks,

Dr Bob

Shurman, Joe Title: chair pain mgt
Organization: scripps memorial hospital
Date: 04/08/2012
Comment:
please continue coverage of existing tens coverage so my patients will have access to a cost effective, minimal risk therapy.....Without Tens many of my patients will have to increase their meds and some will end up with surgery or expensive interventional procedures
Ho, F Title: Account Executive
Organization: Zynex Medical
Date: 04/08/2012
Comment:
I am a representative for Zynex Medical and I provide Tens Units to patients including Medicare Patients. I can tell you so many patients and offices have given me so much feedback on how Tens has helped treated their low back pain and has helped them either decrease their pain medication or eliminate their total use of pain medication all together. There has also been many studies to prove this as well. I have been told many times that patients would much rather use a Tens Unit than to be on

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Barbier, Gerard Date: 04/08/2012
Comment:
I believe the changes proposed would seriously hamper the doctor-client relationship. It would eliminate alternatives which the doctor could prescribe for the patient. Pain is not always completely treatable by medication, and the prolonged side effects of some medication make the situation more difficult. Please reconsider.
lefkovitz, joshua Title: president
Organization: Pain Management Technologies, Inc
Date: 04/08/2012
Comment:
Our firm has extensive experience treating patients with chronic low back pain utilizing TENS unit therapies. A significant portion of our patients are utilizing TENS treatment day-in and day-out, for long periods of time to treat their low back pain conditions. Restricting coverage of TENS would be a poor decision that would adversely affect the patient and we feel, would ultimately increase the costs associated with treating pain alternatively through drugs or surgeries. Thus, having a

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Miller, Matthew Title: PA, RN
Date: 04/08/2012
Comment:

I'm a PA working in a neuroscience and spine center and I don't kow how many of our patients would function without portable, at home tens. We run these as a short trial to ensure effectiveness and make sure the patient likes the therapy.

This is one of the biggest leaps I've seen cms take. To just stop coverage on this quite useful therapy does not make sense at all.

So many patients rely on tens therapy to get through day to day work and activity it would truly be a

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Miller, Matthew Title: PA
Date: 04/08/2012
Comment:

Tens is an abosolute must have for me in my clinic when it comes to patients with CLBP. We often will try it in the clnic first to see if it works. If we fill it is effective the patient gets a home unit. This way we have roughly a 80% or so effectiveness rate which I feel is quite high. Most of these patients cut down on pain pills and have quite a bit of relief.

I'm also more than suspect about this one study used to make this decision. It is amateur at best and it is surprising

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Miller, Matthew Title: MD
Date: 04/08/2012
Comment:

I am an MD and a Clinical Assistant Professor of Medicine and I'm shocked by this ruling. No therapy is 100% effective but from what I have seen over the years tens has made quite a positive impact on patients with chronic low back pain.

Why not make the coverage criteria easier and more cut and dry? I know these are already done as a rental and they are not a very expensive item so it is hard to understand the strategy here

I know cms needs to cut costs but this is not

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Miller, Matt Date: 04/08/2012
Comment:
I'm an MD extender at a large clinic and tens has became a great modality for us for patients suffering chronic low back pain. Does it work for every patient? No. But it does work for many. Not only that it is totally safe and can often help get some of these folks off pain pills. We know the definite benefits post surgical but I strongly urge you to reconsider this stance on CLBP. Many patients' need portable tens to do their jobs and complete daily activities.
ESTEVEZ, ELENA Date: 04/07/2012
Comment:

se que es muy buena la maquina pero es un poco complicada de usar solo se uso al principio con el terapista

The machine is very good but it is a little complicated to use unless you use it first with a therapist

Miller, Matt Date: 04/07/2012
Comment:

I'm writing as a very concerned [PHI Redacted] healthcare professional. [PHI Redacted] Stopping coverage of tens would be detrimental to so many patients.

Beyond that I am a nurse at a pain management clinic. So many patients are hooked on pain pills and tens is a great way to get lasting releif without all the pills. Not only do tens bring pain relief but I truly feel they save lives.

My docs are shocked at this announcement. Not only

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FREEMAN, FRIEDA Date: 04/07/2012
Comment:
I have read of the proposal by Medicare to discontinue payment for tens units and supplies for the units. [PHI Redacted] I would request that you investigate the pluses of this type of therapy and hope in earnest that [PHI Redacted] would provoke some thought in the your proposal to discontinue payment for this device.

This comment was submitted within the comment period but not posted until June 18, 2012 due to technical difficulties.

McGloughlin, John Title: Retired
Date: 04/07/2012
Comment:
[PHI Redacted] I do not want to see coverage for this device changed or discontinued by CMS

This comment was submitted within the comment period but not posted until June 18, 2012 due to technical difficulties.

Kozak, John Date: 04/06/2012
Comment:
TENS has been around for decades, has been effective for many of my patients and has no significant side effects. By disallowing this modality to anybody who is not enrolled in a clinical study will only cause me to prescribe more medications with possible side effects or perform more procedures at greater expense. There already is a one month trial procedure in place to make sure a patient benefits from TENS before purchase. That prevents Medicare from purchasing units when they are not

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Hammer, Dale Date: 04/06/2012
Comment:

TO CMS VIA EMAIL/Web Posting

Brijet Burton, MPP, MS, PA-C
Sarah Meisenberg, MSPH
Susan Miller, MD
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244 T 800.321.9549

Dear Ms. Burton, Ms. Meisenberg, and Dr. Miller:

DJO Global, Inc. (DJO) appreciates the opportunity to submit comments on CMS's Proposed National Coverage Analysis (NCA) regarding Transcutaneous Electrical Nerve Stimulation (TENS) for

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Schlact, Norman Title: Manager of Rehabilitation Services
Organization: Suncoast Medical Clinic
Date: 04/06/2012
Comment:
As a practicing Physical Therapist for the past 20 years, I can attest to the effectiveness of TENS for chronic low back pain. Obviously, there is no one treatment that is 100% effective in eliminating low back pain, but approximately 75% of my patients experience beneficial relief of their pain with the help of TENS, allowing increased function and activities ability. I provide TENS as an adjunct to other therapies, such as exercise, which enhances patient compliance and follow through.

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Sehlinger, Christiane Title: Billing Analyst
Organization: Alliance Medical Solution
Date: 04/06/2012
Comment:
Will Medicare coverage of Tens units hinge on the diagnosis code used? The article notes chronic lower back pain and not covering a tens unit in the event another diagnosis such as cancer (disease) is causing the back pain, but will a diagnosis such as a herniated disc or degenerative disc disease be considered for coverage?
Fulton, DO, MS-HCA, Dr. Cheryl Title: Family Physician with Mercy Health Systems of Nort
Date: 04/05/2012
Comment:

CMS - I request your consideration to NOT eliminate coverage for TENS units for chronic low back pain in our medicare population. I am a family physician in Lowell, Arkansas, and have been practicing medicine since 1998. I work 'in the trenches' daily with our medicare patients, and see chronic back pain daily in my office, and in the hospital. Back pain is a frustrating, chronic problem for many of the patients we serve, and there often is no quick-fix. I have heard myself in lectures and

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Vraa, Matthew Title: MPT
Date: 04/05/2012
Comment:
I am very concerned about the possibility of Medicare restricting the coverage of TENS for patients suffering with chronic low back pain. As a physical therapist, I have seen the positive effects of this modality on hundreds of my own patients who suffer from chronic pain. It has proven over and over to be a very effective non-narcotic adjunct to many of patients with low back pain.
It is very important to understand that one single article in Neurology (Dubinsky and Miyasaki) based

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noll, barbee Title: medical sales distributor
Organization: Pain and rehab tech
Date: 04/05/2012
Comment:
Over the past 6 years I have found TENS for low back pain extremely beneficial for my patients--helping with pain, increasing range of motion and flexibility and decreasing stiffness.
Blanton, Susan Date: 04/05/2012
Comment:
I have been in the medical field for 23 years now. 10 of those years I have been helping patients find options for the relief from CLBP. It has been my experience that TENS devices have been a God Send for the majority of these patients. It allows them to have control of their pain management program,in a sense, without the effects of western drugs, which we all know have many negative effects on the elderly. I appall the very thought of this technology being taken away from these patients

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Emadian, Seyed Title: Neurosurgeon
Organization: Premier Neurosurgery & Spine Center
Date: 04/05/2012
Comment:

To Whom It May Concern:

I would like to lend my support to Isokinetics, Inc. to overrule your medical decision that TENS is appropriate to treat chronic low back pain. This decision by Medicare seems to be a substitute for the doctor's judgment regarding what is the best treatment for our patients. The TENS unit has been approved by the FDA as safe and effective for chronic low back pain for at least three decades and I feel that it has its place in the treatment plans of these

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Abraham, James Title: Physician
Organization: Little Rock Diagnostic Clinic
Date: 04/05/2012
Comment:

I am a rheumatologist in Little Rock, Arkansas and have been practicing at the Little Rock Diagnostic Clinic for 20 years. During that time, I have seen many patients with chronic pain of different sorts, including chronic back pain. In my experience, I have found little use for transcutaneous electrical nerve stimulation (TENS) and applaud the elimination of existing coverage for this and other unproven and unhelpful (and often expensive) treatments. There is so much waste in health

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Langley, Meropi Title: Nurse Practitioner
Organization: Illinois Regional Pain Institute
Date: 04/05/2012
Comment:
My name is Meropi Langley and I am a Nurse Practitioner at the Illinois Regional Pain Institute. At our practice, we see medicare patients everyday that rely on their TENS unit for their chronic low back pain. TENS unit is an essential part of our treatment plan especially for elderly patients that either can not tolerate pain medications or are not beneficial. TENS unit is a tool that a patient can use independently which is an important part of pain management as it helps the patients feel

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Rabe, Ken Title: DO
Organization: AZ Pain Treatment Centers
Date: 04/05/2012
Comment:

I utilize home TENS units in my practice for relief of chronic pain and feel that TENS is beneficial and cost effective.

There are many issues with this proposal:

  • Represents government interference in the doctor-patient relationship founded on the physician's uncompromising commitment to patient welfare. By severely restricting treatment alternatives currently available for treating CLBP patients, the government is substituting its judgment for my judgment

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Cody, Brian Title: Physicians Assistant
Organization: AZ Pain Treatment Centers
Date: 04/05/2012
Comment:

I utilize home TENS units in my practice for relief of chronic pain and feel that TENS is beneficial and cost effective.

There are many issues with this proposal:

  • Represents government interference in the doctor-patient relationship founded on the physician's uncompromising commitment to patient welfare. By severely restricting treatment alternatives currently available for treating CLBP patients, the government is substituting its judgment for my judgment regarding

    More

  • Nathan, Campbell Title: Chiropractor
    Organization: AZ Pain Treatment Centers
    Date: 04/05/2012
    Comment:

    I utilize home TENS units in my practice for relief of chronic pain and feel that TENS is beneficial and cost effective.

    There are many issues with this proposal:

    • Represents government interference in the doctor-patient relationship founded on the physician's uncompromising commitment to patient welfare. By severely restricting treatment alternatives currently available for treating CLBP patients, the government is substituting its judgment for my judgment

      More

    Rosen, Ryan Title: Physician
    Organization: Pain Management Associates
    Date: 04/05/2012
    Comment:
    TENS units should remain covered under Medicare/Medicaid Policies. It helps aid in reducing oral use of medications and increases patient's quality of life.
    seguin, greg Title: controller
    Organization: b & h medical
    Date: 04/05/2012
    Comment:
    the number of patients that return year after year for new electrodes is a testimonial to the relief that the tens unit provides,this alone speaks volumes.
    H, Christin Date: 04/05/2012
    Comment:
    For many people with chronic pain increasing the level of drugs to deal with the pain may not be the best solution. TENS units are a safe, cheap alternative to drugs for the relief of chronic pain. Although not everyone finds them effective many people, including my myself, wouldn't be without one! I have several family members and friends who swear by the TENS Unit because it has done amazing things for their pain; things that couldn't be accomplished without increasing their pain medication.

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    Sparacio, Eva Date: 04/05/2012
    Comment:
    My [PHI Redacted] has suffered with lower back pain for many many years. Use of a TENS unit relieves her pain so that she can sleep at night.
    Bongiorni, Dennis Title: Chief of Physical Therapy
    Organization: Durham VA Medical Center
    Date: 04/05/2012
    Comment:
    In the VA system we use TENS units for patients with chronic pain issues. I can say that over 90% of the patients I instruct in use of the TENS unit have reported feeling better and have had a decrease in their pain level. I would hate to see taking this adjunct therapy away from these patients. I explain to them that this is not a cure for their pain. Whatever is causing the pain is still there but the TENS unit is a way of them coping with the pain. There is literature support for the

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    Saxon, Lacey Title: Account Manager
    Organization: MEDS
    Date: 04/05/2012
    Comment:
    I have seen hundreds of individuals receive relief from the use of the MEDS tens unit. I deliver to 20 patients a week. 15 on average for lower back pain. I then follow up with a call after 2 weeks to see the result. All are finding relief from the TENS.
    Benson M.D., Stuart Date: 04/04/2012
    Comment:
    We physicians at WRDC ( Washington Regional Diagnostic Clinic) in Bentonville, Arkansas would like to inform you of our concern of CMS decision to eliminate TENS therapy for chronic low back pain. This modality has been effective in treating our patients, avoiding use of invasive procedures and narcotic analgesia which can lead to multiple problems in our aging population that we feel will actually increase expenditure of CMS in the long run. WE ARE AGAINST ELIMINATION OF TENS COVERAGE FOR

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    Roberts, Rhonda Date: 04/04/2012
    Comment:
    [PHI Redacted] In this day when so many chronic pain patients are taking too many prescription drugs, I was shocked to hear CMS was considering doing away with TENS. It is less expensive than drugs, safer and more affective...it works immediately. Why take such a simple fix away from so many people. PLEASE DON'T limit coverage.
    Dinger, Stephen Title: Dr. Stephen Dinger
    Organization: Spine and Pain Center of San Antonio
    Date: 04/04/2012
    Comment:
    TENS units have been a vitale modality for treatment of my patients with chronic low back pain. They provide an extremely safe and easy to use modality which helps patients with there condition, but also limits polypharmacy. Patient response to home TENS units has been excellent with chronic low back pain.
    HERZIG, CHRISTINE Title: Account Executive
    Organization: Advanced Rehabilitation Technologies
    Date: 04/04/2012
    Comment:
    I am a retired Physical Therapist Asst, worked in the field over 30 years. I have treated many chronic low back suffers. The TENS unit has allowed the majority of them to gain back their lives. Most of these patients have been told by their doctors there isn't any more they can do and they just have to learn to live with the pain. One man told me just recently that he had given up on life and went to bed to die. After receiving the TENS unit he is now up doing gardening and is planning a

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    Tarbox, Peter Title: DR. Peter Tarbox Neurology
    Organization: Neurology Consultants of San Antonio
    Date: 04/04/2012
    Comment:
    I anticipate that TENS will significantly reduce spine related pain, paresthesias and radicular symptoms if used as directed daily.
    Shoffer, James Date: 04/04/2012
    Comment:
    Transcutaneous Electrical Nerve Stimulation (TENS) has been very beneficial for the treatment of chronic pain. This modality allows patients to live a more normal life without the use of narcotics in many cases. Without TENS patients may be subjected to more painful trreatments, possible injections or other modalities. Please continue to allow for the use of TENS units.
    Seymour, Lynn Date: 04/04/2012
    Comment:
    I believe that TENS should continue to be a treatment modality for patients with chronic low back pain, as it has reduced the number and frequency of other medical visits, use of narcotics/pain medications, improved their functional mobility, quality of life, and ability to perform their daily activities. This has been demonstrated in numerous patients when all other treatment options and techniques in PT have failed to achieve these results.
    Darah, Jeff Title: President
    Organization: Darah Medical Equipment and Supplies LLC
    Date: 04/04/2012
    Comment:
    We have been fitting patients with TENS units for 6 years. Many of our patients consistantly express approval of how well the TENS unit relieves their back pain. A great many of our physicians utilize the TENS unit for an alternative to prescription pain meds. The TENS unit is an effective and safe way of fighting chronic back pain.
    Lewis, Diane Date: 04/04/2012
    Comment:
    [PHI Redacted] If THIS is not enough reason to cover it for others, then let me say I have worked with other people in pain in my career as a nurse and most of them have received significant relief as well.
    Bradley, David Date: 04/04/2012
    Comment:
    TENS units are a necessary part of treatment of patients with both acute and chronic low back pain. These units allow the patients to perform home self-treatments. I find that patients with home TENS units will utilize fewer medications and will seek less professional help. Additionally, my patients with the TENS units tend to stay more active and less sedentary; this point is exceptional important because not only does activity improve low back pain but it improves over health: the CDC

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    Harris, Richard Title: owner
    Organization: Advanced Rehabilitation Technologies
    Date: 04/04/2012
    Comment:
    I have been supplying tens units for treatment of low back pain through Doctors Prescriptions for the past 12 years. We have received hundreds of testamonial letters from patients about how the relief of there back pain due to the use of the machine has reduced there use of pain medication to almost nothing related to this problem. It is always easy to say something is unneccesary if you do not need it yourself. We see the positive results of this product every day. I always thougt the goal

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    Attebery, Ray Date: 04/04/2012
    Comment:
    To place limitations on using TENS or any other device to alleviate painful conditions is tantamount to living in a totalitarian society. It is obvious that those who would pass such a thing have never experienced real back pain. If this passes, and there is a God, I hope he inflicts back pain on every individual who supports this ridiculous proposal.
    Schluterman, MD, Keith Date: 04/03/2012
    Comment:

    I am writing as a regular prescriber of TENS units for low back pain management. Low back pain is one of the most frequent pain complaints and one of the most common reasons for missed work and productivity. TENS usage allows patients to manage their pain and often return to work, social activities, etc. This treatment lessens the need for addictive opioid analgesic (narcotic) medications as well. This treatment can be used chronically and is cost effective. Home usage allows patients to

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    Sears, Christine Title: Physical therapist
    Organization: Northwestern Medical Center
    Date: 04/03/2012
    Comment:
    Please reconsider your proposed decision regarding coverage of TENS for chronic LBP. I have been practicing physical therapy for 17 years and feel TENS is moderately to highly effective at decreasing pain and thus improving functional mobility of individuals with chronic LBP. As with much of the current literature/research, it is challenging find information that conclusively supports many medical and physical therapy interventions. I support your decision to cover use of TENS while used in a

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    Alvarado, Sergio Title: Dr. Sergio Alvarado
    Organization: Spine and Pain Center of San Antonio
    Date: 04/03/2012
    Comment:
    TENS is an excellent non-pharmacological, non-interventional treatment option for patients with acute and chronic low back pain especially when associated with muscles spasm. It is my preference to use TENS rather than muscles relaxer medication or opioids if possible.
    Andreades, Stephen Date: 04/03/2012
    Comment:
    Low back pain in patients can be chronic of nature and debilitating. In the US more work is missed on a daily basis due to low back pain than any other condition. Modalities such as tens unit on a daily weekly and intermitent basis can and should be of use and medical necessary.
    Kubitz, Peter Title: D.O.
    Organization: Arizona Center for Pain Relief.
    Date: 03/23/2012
    Comment:

    As a practicing pain physician, there is no doubt that TENS works for patients. Does it work for all? No. Does anything in pain management work for all? No. With the inherent and prevalent issues pertaining to pain medications, especially in the elderly, it would be a shame to take away a pain relieving modality that can limit someones exposure to more toxic and problematic treatment options. Studies regarding TENS will never be very decisive, as pain is such a subjective problem with too

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    Aurora, Patricia Date: 03/22/2012
    Comment:
    [PHI Redacted] Why would Medicare stop paying for the necessary supplies? I am sure many people would need to go onto medications if they no longer had their TENS to use.
    miller, robert Title: pres
    Organization: personal opinion
    Date: 03/22/2012
    Comment:
    Why make this more complicated than it is. the items have been over-prescribed for years due to the high reimbursement rate, not due to their effectiveness. Firs,t reduce the reimbursement to a one time sale, at a REASONABLE price, well under $100. then develop a question and answer form THAT YOU FEEL COMFORTABLE WITH, that the physician must fill out with the patient present during a face to face office visit. clearly indicate on the form if the patient will or will not qualify with the

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    Tessean, Ryan Date: 03/21/2012
    Comment:

    In 14 years of practice as a Physical therapist I have found TENS to be extremely helpful in reducing pain, inproving daily function and reducing the amount of pain medication taken by my patients. Contary to what is stated in your report, I very seldom need to see patients for more than one physical therapy visit to allow for proper independant use of TENS by the patient.

    I have found that TENS has reduced the number of physical therapy visits needed at times and has allow

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    Salem, Mike Title: CEO
    Organization: Isokinetics, Inc.
    Date: 03/18/2012
    Comment:

    Dear Medicare

    Currently, most, probably 99 percent of insurance companies will pay for a Tens unit for a patient with chronic low back pain. In fact, recently, Blue Cross Blue Shield of Texas and Illinois re instated coverage for tens units.

    In order for a patient to receive a tens unit for Medicare,the physician must write an order for a 30 day trial, then within 30-60 days, upon a follow up, when the patient and the physician decide that the tens unit is effective, then

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    Goodell, Heather Title: President
    Organization: Goodell Physical Therapy & Fitness Training
    Date: 03/17/2012
    Comment:
    I am a physical therapist that utilizes TENS for patients with Chronic Low Back Pain. Although the back pain may not resolve with the use of TENS it does allow them to reduce their pain medication and offers a less invasive/non-systemic treatment option to help them cope with their pain. I would recommend CMS calculate the cost savings they would achieve by reducing prescriptions for pain medications and really look at how much patients are able to cut back their medication when able to use

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    Claes, Dale Date: 03/16/2012
    Comment:
    [PHI Redacted] It is effective at controlling pain for a limited time. The non-steroidal anti-inflamatory agents are not affective at reducing pain. [PHI Redacted] Other neuroleptic medications have caused major side-effects. Please maintain the availability of patients to receive a TENS unit.
    Drevyn, William Title: PTA, Medicare Compliance Ofcr,Clinical Instructor
    Organization: Physical Therapy Dept, UMH
    Date: 03/16/2012
    Comment:
    If this standard is to be applied based on "chronicity", will cervical "chronic" conditions eventually follow suit?
    Karvel, RN, BSN, Ryan Title: Director of Nursing
    Organization: Novocur Pain Management Solutions
    Date: 03/15/2012
    Comment:
    I am the Director of Nursing at a successful pain management company. We have many patients that use TENS at home; they routinely report that TENS reduces their perception of pain. Comprehensive pain management addresses physical, physiological, and emotional sources of pain. While the medical community continues to research and gain new knowledge about pain, it would be inaccurate to state that pain is understood completely. CMS has a responsibility to make sure health care resources are

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    Flyr, Barbara Date: 03/14/2012
    Comment:

    After reading your information on TENS I was appalled that the study shows it to be ineffective. I have been an RN for 36 years and have seen many people have relief of pain along the nerve pathways using the TENS. [PHI Redacted] and can assure you it is a worthwhile treatment. Not all modalities of treatment work for everyone but they work for some of the people. I will soon be of Medicare age myself and believe if you have treatment that works for some people why would

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    Kamp, Mike Date: 03/14/2012
    Comment:
    As a manager of a rehab clinic, I have seen significant cost savings through patient use of TENS units for low back pain. I would propose that the limitation should be on the # of skilled therapy visits allowed to issue a TENS unit rather than reducing a modality that can reduce or eliminate multiple sesion of skilled therapy or oral medications. With the push towards low cost alternatives, this seems a step in the worng direction. To issue a TENS unit, the patient only needs to see a

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    Duyck, PT, Allen Date: 03/14/2012
    Comment:
    In 27 years as a physical therapist I have found that TENS units are at times helpful in the management of chronic low back pain. Studies that show even minimal efficacy of this modality with the chronic low back pain population should be heavily weighted in coverage decisions because in true chronic pain patients nothing else has helped. To rule that patients must be enrolled in a study to receive the modality dictates that they must agree to be a research subject in order to be treated.

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    Blasiole, Joseph S. Date: 03/13/2012
    Comment:

    [PHI Redacted] I have seen many results with this device. It reduces the need for medication and allows for function and independence for the those who suffer with this condition. Surgery is sometimes indicated but to avoid surgery and the altering the low back is ideal. This modality allows for patients (not all) to live a productive life without the need for surgery. This used with Physical Therapy is ideal. Joseph S. Blasiole