National Coverage Analysis (NCA) View Public Comments

Acupuncture for Chronic Low Back Pain

Public Comments

Commenter Comment Information
DeLorme, LA Title: Board Member
Organization: The National Center for Acupuncture Safety and Integrity
Date: 08/14/2019
Comment:

August 14, 2019

Tamara Syrek Jensen, JD, Director, Evidence and Analysis Group
David Dolan, Lead Analyst, Evidence and Analysis Group
Susan Miller, MD, Lead Medical Officer, Evidence and Analysis Group

RE: National Coverage Analysis (NCA) for Acupuncture for Chronic Low Back Pain (CAG- 00452N)

Dear Ms. Syrek Jensen, Mr. Dolan, and Dr. Miller:

On behalf of the Board of Directors of the National Center for Acupuncture Safety and

More

Musser, Courtney Date: 08/14/2019
Comment:

To whom it may concern:

This is an amazing opportunity for acupuncture to show its effectiveness for chronic low back pain, but I find it imperative that it is limited to licensed acupuncturist as credited by NCCAOM. Other health professionals have limited class hours and training on proper treatment using all of the tools acupuncture has to offer. Those credited by NCCAOM have atteneded an accredited graduate school that is a the least amount of time 3 years, and gives a much

More

Gomez, Claudia Title: Acupuncture Physician
Date: 08/14/2019
Comment:

First of all I want to thank the CMS for their consideration of this topic. This represents a giant step towards the incorporation of acupuncture into national health care.

My petition/comment is regarding the section that includes “auxiliary providers”: to please be changed to more clearly name “Licensed Acupuncturists or Acupuncture Physicians”. The qualifications for auxiliary providers exactly describe this licensure group.

Also I would like to comment/ask that the

More

Blewett, Susan Title: Dr
Organization: Five Branches University
Date: 08/14/2019
Comment:
As an acupuncturist I feel strongly that all licensed acupuncturists should be included in this study. The California Acupuncture Licensing Exam should be recognized as equivalent to the NCCAOM exam for the purposes of this study. In addition licensed acupuncturists need to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
Pole, Carolyn Title: Licensed Acupuncturist
Organization: Acupuncture & Healing Arts Center
Date: 08/14/2019
Comment:

I am a Licensed Acupuncturist practicing in California as a Primary Health Care Provider since 1994.

I support Medicare adding Acupuncture as an mandatory benefit.In fact I worked with a coalition of Acupuncturists for 3 years from 1994 to 1997 towards this goal. We complied with everything asked of us by Medicare, including working with the FDA and getting Acupuncture needles taken off the experimental device list. At that time Acupuncture Needles were the lowest adverse event

More

Melton, Daniel Title: Dr.
Date: 08/14/2019
Comment:

Dear CMS,

I am writing to advocate for the inclusion of acupuncture for chronic low back pain (“CLBP”) into Medicare. In this comment I will focus on:

  1. The growing consensus that acupuncture is helpful for CLBP and the need for public policies to reflect that consensus.
  2. Navigating common concerns with regard to acupuncture studies, particularly in RCTs.
  3. The importance of specifying that Licensed Acupuncturists are included as providers in

    More

Piper, Yvonne Title: DiplOM, DOM, LAc
Organization: OM Wellness
Date: 08/14/2019
Comment:

David Dolan
Susan Miller, MD
U.S. Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

Aug 14, 2019

RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

Dear Dr. Miller and Mr. Dolan:

As a Licensed Acupuncturist in the state of Colorado and a Doctor of Oriental Medicine in the state of Colorado, I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain

More

Sylvanson, Jessica Title: L.Ac.
Organization: Here and Now Acupuncture
Date: 08/14/2019
Comment:

Dear Mr. Dolan and Dr. Miller,

My name is Jessica Sylvanson and I am a licensed acupuncturist in the state of Colorado where I have practiced for 13 years. I am happy to see that CMS is proposing to conduct this study on Acupuncture for chronic low back pain, as it is something I treat regularly with very favorable outcomes. I am hopeful that this treatment will be available to Medicare and Medicaid patients, and help give them alternatives to opioids.

However, I am

More

Wang, yuxin Date: 08/14/2019
Comment:
  1. We want all licensed acupuncturists to be included in this study.
  2. We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
  3. We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
Simpson, Dylan Date: 08/14/2019
Comment:

We want all licensed acupuncturists to be included in this study

We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.

We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists

Ehrhart, Ursula Title: student
Date: 08/14/2019
Comment:
We want all licensed acupuncturists to be included in this study
We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
Guptha, Leena Organization: 2B Well
Date: 08/14/2019
Comment:
As a PhD candidate studying Acupuncture and back pain, Academic Dean and DO of 29 years looking at the evidence base in peer review journals it is clear that Acupuncture positively impacts pain management and has been shown to have effect up to 18 weeks after - making it a viable option to address the growing opioid crisis in this country. Though there is not an option here to attach a literature review a simple search of acupuncture and low back bain would show the progression of studies over

More

Gale, Megan Title: MSAOM
Organization: The Hospital Practice Handbook Project for Acupuncturists and
Date: 08/14/2019
Comment:

Thank you for the time you have spent reviewing the evidence and reference citations submitted for the Jan/Feb 2019 comment period. I appreciate your decision to require STRICT-A reporting guidelines for future funded research. Thank you.

To your decision about acupuncturists/auxiliary personnel being supervised “auxiliary personnel furnishing acupuncture must be under direct supervision…”, what is your reference point for this? My understanding is that supervisory language is

More

Montague, LaKetta Title: Ms.
Date: 08/14/2019
Comment:
I am excited to see the inclusion of acupuncture as a pain management method for chronic pain. I have benefited immensely from acupuncture treatments to manage my back pain while limiting exposure to drugs, mainly opioids. Acupuncture requires an immense amount of study and practice to obtain therapeutic results, can you please consider requiring a licensed acupuncturist (LAc) to perform the treatments under the guidance of an MD. I do not feel that healthcare disciplines with less than 2

More

Hsiang Weiss, Li-Lan Title: Licensed Acupuncturist
Organization: Silent Dayze Music
Date: 08/14/2019
Comment:

David Dolan
Susan Miller, MD
U.S. Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244

August 14, 2019

RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

Dear Dr. Miller and Mr. Dolan:

As a Licensed Acupuncturist in private practice in the State of North Carolina since 2005 and a Diplomate in Oriental Medicine with the National Certification Commission of Acupuncture and

More

Halloran, Eileen Date: 08/14/2019
Comment:
As an incoming student of Acupuncture I spent time shadowing other acupuncturists and found several of their patients were coming to them with chronic pain. Many of them with back pain. In today's economic environment I don't think anyone would be spending money on a treatment that didn't work. They seek out acupuncture because they are desperate, they stay because it's effective.
Katlin, Susan Title: L.Ac, RN, DACM
Organization: Suzi Katlin Acupuncture & Chinese Herbal Medicine
Date: 08/14/2019
Comment:
Thank you for consideration of this topic. This represents a massive step towards the incorporation of acupuncture into national health care.
  • Please change “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent. Having individuals practicing acupuncture who is not licensed by the state will increase complications and risks associated with acupuncture. No D.O , naturopath doctor, chiropractor, physical therapist has the same extensive training

    More

  • Zilber, Stephen Title: LAc
    Organization: Modern Ancient Medicine
    Date: 08/14/2019
    Comment:

    While as a licensed acupuncturists I strongly support the proposed study of acupuncture for chronic low back pain and would like to thank the CMS for its consideration of this topic, I am also concerned about some of the details in the proposal.

    The requirement of NCCAOM certification beyond California state licensure is an onerous burden that will exclude many qualified practitioners from participating.

    In addition, the provision that licensed acupuncturists be under

    More

    Vinjamury, Sivarama Prasad Title: Licensed Acupuncturist
    Organization: Southern California University of Health Sciences
    Date: 08/14/2019
    Comment:
    The proposed document would allow certain non-acupuncturists to provide acupuncture services and excluded California licensed acupuncturists who have not also been certified by the NCCAOM. This is unacceptable. Also, the document labeled licensed acupuncturists as "auxiliary personnel" and requires supervision by Physician Assistants and Nurses, who have no training in acupuncture. This is not appropriate.
    However, I support the initiative of CMS in investigating the role of acupuncture

    More

    Gustafson, Amberlee Date: 08/14/2019
    Comment:

    A review of literature on acupuncture for pain quickly reveals severe design flaws when licensed acupuncturists are not included in the design and execution of acupuncture trials. Many studies do not take into consideration the breadth of information that acupuncturists have on the subject, including nuances of theory, diagnosis, and implementation, and the design is often overly simplistic to the point of making the results useless.

    I'm very excited that more acupuncture research

    More

    Tom, Jean Title: Licensed Acupuncturist
    Organization: Jean Tom Acupuncture
    Date: 08/14/2019
    Comment:

    Dear Mr. Dolan and Dr. Miller:

    I am a licensed acupuncturist in California and I am nationally certified by the NCCAOM as a diplomate in Oriental Medicine. I practice in Pasadena, CA. I am also a member of CalATMA. Thank you for requesting comments regarding efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare.

    I have the same concerns as CalATMA, as stated in their letter dated 8/4/19 to you, regarding the

    More

    HURME, ERIN Title: DAOM, LAC, LMT
    Organization: ASNY
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    As a Member of the Acupuncture Society of New York (ASNY) and the American Society of Acupuncturists, I applaud efforts by CMS to study the effects of acupuncture for chronic low back

    More

    Shi, Rui Title: Acupuncturist
    Date: 08/14/2019
    Comment:
    I having been working as an acupuncturist since 2007. Low back pain is one of most common issues I have been treating for so many years. I am confident to say that acupuncture really works for chronic lower back pain!
    LAO, JING Title: Acupuncturist
    Organization: Silicon Valley Acupuncture Professional Corporatio
    Date: 08/14/2019
    Comment:

    Acupuncture is effective treatment method for low back pain. It can dredge the Qi and blood and alleviate inflammation of locally.I treats many patients well due to low back pain.

    Acupuncturist should take part study in this field.

    Suarez Cormier, Julie Title: Licensed Acupuncturist
    Organization: Vermont Community Acupuncture
    Date: 08/14/2019
    Comment:
    Thank you for considering acupuncture for the treatment of low back pain. Licensed acupuncturists are the most qualified to provide acupuncture services, as we have the most extensive training. In Vermont we are considered direct entry providers. We do not require supervision by an MD. We must have completed a 3 year education program with at least 1750 hours of study. I do understand that your trial studies may require supervision, and respectfully ask that the supervision is provided by

    More

    Wegner, Tory Date: 08/14/2019
    Comment:

    To David Dolan, Dr. Miller, and team

    Thanks to CMS for studying the effects of Acupuncture for chronic low back pain! Having my Doctorate in Acupuncture and Chinese Medicine combined with over 13 years of clinical experience, I know first hand how effective acupuncture treatments can be for low back pain and other pains.

    While this is an exciting first step, based of the wording of the initial memo I have some concerns and comments.
    First the wording about WHO is

    More

    Skultety, Evelyn Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Cone, Tracy Title: L.Ac
    Organization: santa cruz wellness
    Date: 08/14/2019
    Comment:
    Please specify in the new policy that ALL acupuncture must be performed by licensed acupuncturists who do NOT need supervision by other licensed practitioners; we are already primary care physicians in California and our status should not be downgraded in any way. Additionally, the requirement that practitioners have both the CALE and NCCAOM certification is superfluous and unnecessary.
    Boyd, Janet Organization: Self
    Date: 08/14/2019
    Comment:

    I am a practicing L.Ac. In the states of Hawaii, NY and CA. I am so happy to hear that there is a study on the affects of acupuncture on low back pain.
    I am concerned that the study will be conducted with many practitioners with lower training hours than an L.Ac. In the state of Hawaii only L.Ac’s can practice acupuncture. No MDs,No PTs no one except trained licensed acpincturist. My trading consisted of 4 years of graduate Masters of Science. Approx 3,000 plus hours of training.

    More

    DuCray, Carolynn Date: 08/14/2019
    Comment:
    I am very concerned regarding the language used for this study of acupuncture. We licensed acupuncturists are highly trained to perform acupuncture, and we do not require oversight from other medical professionals who have far less or no training in acupuncture.
    I would appreciate a change in the structure of the study so that it can truly be done to a higher standard, using licensed acupuncturists to perform the study.
    Xin, Jessie Date: 08/14/2019
    Comment:
    I am a member of CalATMA, from my experience, the patients prefer to be treated by a licensed acupuncturist.
    Me, Eleonor Title: DAOM
    Organization: Five Branches University- Santa Cruz campus
    Date: 08/14/2019
    Comment:
    Acupuncture and Chinese medicine are excellent for the treatment of chronic debilitating conditions.
    Chang, Chung Young Organization: 1962
    Date: 08/14/2019
    Comment:

    The California Acupuncture License has never been licensed by NCCAOM, so the above regulation makes California acupuncturists unable to participate the Standards for Reporting Interventions in Controlled Trials of Acupuncture (STRICTA) guidelines. ! I hope CMS.gov will amend this rule!

    Acupuncture treatment begins with acupuncturist, not by Western Physician assistants, nurse practitioners, clinical nurse specialists or other medical personnel; therefore, acupuncturists should be

    More

    Wu, Stella Title: LAc
    Organization: APA HealthAssociates
    Date: 08/14/2019
    Comment:
    Licensed acupuncturists or state equivalents who carry an active and unrestricted license in the state of practice may provide acupuncture.
    Brown, Tamara Organization: The Bamboo Clinic
    Date: 08/14/2019
    Comment:
    Please be sure that licensed acupuncturists are providing acupuncture in this study. L.Ac's receive a minimum of 4 years of graduate school in the practice of acupuncture and would be more specialized and more skilled and so more likely to get therapeutic results than a lesser trained practitioner. The study should use best possible care. MDs, PAs and PTs are not sufficiently trained unless they have completed the full Masters or Doctorate degree in Acupuncture.
    Burgess, Becky Date: 08/14/2019
    Comment:

    Dear Dr. Miller and Mr. Dolan,

    I am so grateful for the efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a Licensed Acupuncturist (L.Ac.) I want to seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below: Physician assistants, nurse practitioners/clinical nurse specialists (as identified in 1861(aa)(5)), and auxiliary personnel may

    More

    Grimm, Kellen Title: Licensed Acupuncturist
    Organization: North Node Clinic
    Date: 08/14/2019
    Comment:
    Thank you for going forward with the acupuncture for low back pain study. It is exciting to see CMS interested in investigating this topic. Licensed acupuncturists are the most appropriate providers to be listed in the study, as they are fully trained in Chinese Medicine and acupuncture. Supervision is best provided by MDs instead of NPs, chiropractors or physical therapists.
    Phipps, Kristen Title: L.Ac.
    Organization: Wasatch Community Acupuncture
    Date: 08/14/2019
    Comment:

    I'm an acupuncturist at Wasatch Community Acupuncture, a large non-profit clinic that offers acupuncture on a $15-$40 sliding scale. We are members of the national cooperative called the People's Organization of Community Acupuncture (POCA), that is committed to making acupuncture accessible and affordable. I have been practicing acupuncture for over 8 years and chronic low back pain is one of the most common ailments that we treat. As with any medicine acupuncture doesn't work 100% of the

    More

    KIM, SEONG Date: 08/14/2019
    Comment:
    I want all licensed acupuncturists to be included in this study
    I want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    I want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    PAK, KEI Title: DR
    Date: 08/14/2019
    Comment:
    I want all licensed acupuncturists to be included in this study.
    I want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    I want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists.
    Chi, Hung-Tien Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Von der Muhll, Anthony Date: 08/14/2019
    Comment:

    I am writing to protest dysfunctional errors and misconceptions in CMS's proposed study of acupuncture for chronic low back pain, which, if adopted, would jeopardize public safety by inverting the training/education/licensing hierarchy by putting untrained and unqualified personnel in supervisory positions over licensed acupuncturists who have more training in acupuncture safety and efficacy than mid-level providers.

    The proposed document would allow certain non-acupuncturists

    More

    Harris, Howard Organization: Neonatal Associates
    Date: 08/14/2019
    Comment:
    [PHI Redacted]
    I want to thank the CMS for consideration of adding acupuncture to Medicare so more Americans can receive its benefits.
    The section should change "auxiliary providers" to specifically name "licensed acupuncturists or state equivalent" since this licensure group exactly describes the qualifications for auxiliary providers.Also, the supervision required during the study portion should be done only by an MD.
    Ouchida, Grace Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:

    Thank you for your interest in and considering covering acupuncture for Medicare and Medicaid patients. These patient populations have long awaited the inclusion of acupuncture treatments as part of their insurance plans. So many private insurance plans, and Medical, have already included it in their coverage since it is recognized and has been established by numerous studies that acupuncture is beneficial in the treatment of pain. And as you know, the opioid crisis emphasizes the

    More

    Lee, Peggy Date: 08/14/2019
    Comment:
    * We want all licensed acupuncturists to be included in this study
    * We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    * We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Urcis, Julia Date: 08/14/2019
    Comment:

    The proposed document would allow certain non-acupuncturists to provide acupuncture services, which defeats the purpose of even calling it acupuncture. Acupuncturists set other healthcare practitioners apart because of our unique diagnosis and treatment methods. To an allopathic-trained professional, acupuncture is not well understood and the use of acupuncture methods may or may not have the efficacy that results from acupuncture applied according to it's original theory.

    The

    More

    Geiger, Andrea Organization: Five Branches University
    Date: 08/14/2019
    Comment:

    We want all licensed acupuncturists to be included in this study.

    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.

    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists

    Lee, Xin Ling Date: 08/14/2019
    Comment:
    1. All licensed acupuncturists should be included in this study
    2. Recognition of the California Acupuncture Licensing Exam should be equivalent to the NCCAOM exam for the purposes of this study.
    3. Licensed acupuncturists should be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    huang, bonnie Date: 08/14/2019
    Comment:

    First, we are grateful to the CMS for conducting a clinic trial investigating acupuncture’s effectiveness to treat chronic low back pain in geriatric patients. We understand the need that federal health care legislators seek further evidence for the effectiveness of acupuncture in order to justify federal coverage with medicare. Despite any previous effective clinical trials involving acupuncture in the past, we understand that it needs to be on their terms and conducted within their system

    More

    Fortes-Schramm, Lisa Date: 08/14/2019
    Comment:
    I want all licensed acupuncturists to be included in this study
    I want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    I want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Lavender, Amy Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Stoneman, Kathleen Title: Acupuncturist/Owner
    Organization: Metamorphosis Holistic Health LLC
    Date: 08/14/2019
    Comment:

    It is wonderful that CMS has chosen tostudy the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a a Board Certified and Licensed Acupuncturist (L.Ac.) meeting the criteria listed below::

    • A masters or doctoral level degree in acupuncture or Oriental Medicine from a school accredited by the Accreditation Commission on Acupuncture and Oriental Medicine (ACAOM);
    • a current certification by the National Certification Commission

      More

    Bao, Kexin Date: 08/14/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    Kaneko, Tsuneo Title: Dr.
    Organization: Japanese acupuncture association of California
    Date: 08/14/2019
    Comment:
    I am a member of professional association of Acupuncturists, called Japanese acupuncture association of California
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or

    More

    Humphrey, Janet Title: Dr.
    Date: 08/14/2019
    Comment:

    Thank you very much for considering this topic! I treat people of all ages for pain with acupuncture, with great success. I welcome this opportunity for study of acupuncture’s effectiveness in treating pain. Acupuncture has been treating pain effectively for thousands of years. In fact, there are many published scientific studies available through NIH and PubMed already. A few years ago I did a review of the research into acupuncture and compiled some of it, drawing upon studies that had

    More

    Zimet, Nicholas Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:

    I wish to take a moment to thank the CMS for their consideration of this topic. This represents a massive step towards the incorporation of acupuncture into national health care, which I believe to be an important and effective aspect currently not utilized.

    I would like to ask that the section that includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent”. The qualifications for auxiliary providers exactly describe this licensure

    More

    HA, EUN KYUNG Organization: CalATMA
    Date: 08/14/2019
    Comment:
    1. The proposed document would allow certain non-acupuncturists to provide acupuncture services,
    2. It excluded California licensed acupuncturists who have not also been certified by the NCCAOM,
    3. It labeled licensed acupuncturists as "auxiliary personnel", and
    4. It initiated support for supervision of acupuncturists by physician assistants, nurse practitioners and/or clinical nurse specialists.
    Lee, Sangwon Title: President
    Organization: Angel's Acupuncture & Health Center Inc.
    Date: 08/14/2019
    Comment:
    Acupuncture is on of the part of Asian Medicine and needed study at graduate school. So It can not be practiced by non-acupuncturist like NP, PA.
    They do have any back ground of Asian medicine.
    California is advanced state of developing Asian medicine by State licensed Acupuncturist.
    he, xin Date: 08/14/2019
    Comment:
    As a acupuncturist, I saw so many patients get helped from acupuncture treatment. Especially pain management. It is very common in at the bay area to have low back pain. And a lot of people are looking for a treatment to help them. some of the private insurance are covering the acupuncture treatment for pain management.
    SMALL, DIXIE Title: Doctor of Acupuncture & Oriental Medicine
    Organization: Wellness At The center
    Date: 08/14/2019
    Comment:

    Greetings,

    I am a licensed acupuncturist in the state of Oregon, practicing since 2009, after I completed the required 4-year graduate program in Acupuncture and Oriental Medicine. This was the entry-level required amount of training to be licensed in the U.S. Upon graduation, I had completed 8 years of college-level education. I just completed a 2-year doctorate degree in Acupuncture and Oriental Medicine, and now have a specialization in treating Aging Populations and Women's

    More

    Leahey, Mark Title: President & CEO
    Organization: Medical Device Manufacturers Association (MDMA)
    Date: 08/14/2019
    Comment:

    August 14, 2019

    Via Electronic Submission

    Tamara Syrek Jensen, JD
    Director, Coverage and Analysis Group
    Centers for Medicare & Medicaid Services (CMS)
    7500 Security Blvd., Mail Stop S3-02-01
    Baltimore, MD 21244-1850

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Ms. Syrek Jensen,

    On behalf of the Medical Device Manufacturers Association (MDMA), a national trade association representing hundreds

    More

    Chang, Sharon Date: 08/14/2019
    Comment:
    Hi,
    I want to see all licensed acupuncturists to be included in this study and also recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    The licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists.
    Thank you!
    Zaidman, Ron Title: President & CEO
    Organization: Five Branches University, Graduate School of Traditional Chinese
    Date: 08/14/2019
    Comment:
    We want licensed acupuncturists to be included in this study. They are the most highly trained practitioners of acupuncture in the U.S.
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists.
    Please respect the

    More

    Benjamin, Marvin Date: 08/14/2019
    Comment:

    [PHI Redacted] I want to thank the CMS for your consideration of this important topic if adding acupuncture to Medicare so more Americans can receive it's benefits.

    However, in reading how the CMS proposes to investigate acupuncture here are a few recommendations:

    1. The section that includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent”. The qualifications for auxiliary providers exactly describe

      More

    Lay, Michael Date: 08/14/2019
    Comment:
    I would love to see acupuncture added to Medicare. It is extremely effective in helping with low back pain and is long overdue to be an option.Thank you so much for considering making this a benefit!
    Durrant, Kolin Date: 08/14/2019
    Comment:

    I have some significant concerns about this proposal as follows:

    The proposed document would allow certain non-acupuncturists to provide acupuncture services. Only Licensed acupuncturists in good standing (or those who've completed their Masters of Science in Oriental Medicine, including clinic hour requirements) should be allowed to practice acupuncture.

    • It excludes California licensed acupuncturists who have not also been certified by the NCCAOM. The CALE

      More

    Toomassian, Jenick Organization: relief acupuncture
    Date: 08/14/2019
    Comment:
    I am California licensed acupuncturist and California board exam is harder than NCCAOM so it should be equivalent to NCCAOM. besides any MD or nurse practitioners don't know anything about acupuncture, its diagnosis or treatment, hoe they can supervise?
    Acupuncturist should be independent if the concern is patient health.
    Kim, Chris Title: Mr.
    Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Norberg, Lyna Date: 08/14/2019
    Comment:
    I cannot think of any reason why Chronic low back pain should not be covered by Medicare. It is clearly quite safe and effective as well as cost-effective.
    Thank you for your consideration of this important, well-deserved coverage.
    Jung, Peter Title: D.C
    Organization: CalAtma
    Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Yardley, James Date: 08/14/2019
    Comment:
    Please use Licensed Acupuncturists in your study. This is important to give an accurate look at what trained professionals can achieve versus novice ammeters trying to proactive acupuncture. Thank you.
    Tjiong, Hermanus Date: 08/14/2019
    Comment:
    I am a member of CalATMA. As a California Licensed Acupuncturist providing onsite care for several of Silicon Valley's largest companies, I know the trust our patients place in our superior training and experience. Please include Licensed Acupuncturists in this study.
    Hsiao, Lung Cheng Title: PhD.
    Organization: SCUHS
    Date: 08/14/2019
    Comment:

    As an licensed Acupuncturist for 19 years. Thank CMS for your consideration of this topic that study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare.

    i am seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse practitioners/clinical nurse specialists (as identified in 1861(aa)(5)), and auxiliary personnel may furnish

    More

    KIM, LAUREN Date: 08/14/2019
    Comment:
    Acupuncturist under currently state license are the professionals with abundant clinical experiences with 1:1 patient care for lower back pain. It is absurd to exclude state licensed acupuncturist, while including other healthcare personnel, such as PAs and NPs unless they also hold of proper understanding, education and license qualification.
    Adhikari, Marni Date: 08/14/2019
    Comment:
    As an acupuncturist, I personally have experience working with numerous individuals to help relieve their low back pain. In the course of my ten years in practice, I have seen the majority of back pain sufferers walk out after a few months of treatment with little to no pain. I have helped people get off pain relieving medication. I have seen people who thought their only option was surgery decide that they don't need surgery after all. I know that acupuncture works, and that it's effective

    More

    McGimsey, John Title: LAc
    Organization: AAHOM LLC
    Date: 08/14/2019
    Comment:
    We are LAcs in NC and under contract with the VA treat veterans for Low Back Pain, usually @ 10/10 pain level. These are veterans the VA could not help, thus the referral. We are able in most circumstances able to lower the pain level to 5/10 pain level in 3 treatments. That is our goal to show the veteran that we can help him. Acupuncture works very well for LBP and we document our results.
    Cohen, Liz Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:

    California licensees represent nearly one-third of all licensed acupuncturists (LAcs) in the USA. Along with other relevant stakeholders who will be affected by the decisions made based on the outcomes of these planned studies, we are concerned about problems created by the language of the proposed decision memo and inconsistencies with existing law. We are seeking clarification on several issues as outlined below.

    While 2,147 licensed California acupuncturists are additionally

    More

    Pilinger, Oren Title: Licensed Acupuncturist
    Organization: Peoples Organization of Community Acupuncture (POCA)
    Date: 08/14/2019
    Comment:

    Thank you for considering acupuncture as a potentially effective treatment for chronic low back pain. As a Licensed Acupuncturist, I have worked at several Community Acupuncture clinics across Massachusetts; chronic low back pain is one of the most common reasons people seek acupuncture. I see how much acupuncture improves quality of life for my patients, and appreciate any step toward making this treatment more widely available.

    In almost all states, there are already

    More

    Seitz, Gretchen Title: Dr
    Date: 08/14/2019
    Comment:

    Thank you for the consideration of this topic. This represents a massive step towards the incorporation of acupuncture into national health care and will help direct patients to acupuncture providers with the proper training necessary to serve this patient population.

    Collectively we ask that the section that includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists (LAc), Doctors of Acupuncture (DAOM or DACM) or state equivalent” be included in the

    More

    Borges, Janet Title: Licensed Acupuncturist
    Organization: Thunderbolt Wellness (Private Practice)
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare and Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    Dear Mr. Dolan & Dr. Miller,

    Thank you for efforts made on behalf of the Centers for Medicare & Medicaid Services (CMS) to study acupuncture for chronic low back pain in Medicare populations. Additionally, thank you for the opportunity to provide acupuncture to Medicare patients who are participating in approved trials.

    However,

    More

    Bauer, Matthew Title: President
    Organization: Acupuncture Now Foundation
    Date: 08/14/2019
    Comment:

    August 14, 2019

    We appreciate the opportunity to respond to the Proposed Decision Memo regarding acupuncture for chronic low back pain (cLBP).

    We first would like to ask for the CMS to correct how it classified the Acupuncture Now Foundation (ANF) in the Proposed Decision Memo. You indicated the ANF was one of several “professional associations” who offered comments. The ANF is not a professional association. We are a public benefit educational non-profit (501c3). Our

    More

    Rogers, Jacquelyn Title: Clinic Manager
    Organization: Wasatch Community Acupuncture
    Date: 08/14/2019
    Comment:

    I am the clinic manager at Wasatch Community Acupuncture, a large non-profit clinic that offers acupuncture on a $15-$40 sliding scale in Salt Lake City, Utah. We are members of the national cooperative called the People's Organization of Community Acupuncture (POCA), which is committed to making acupuncture as accessible and affordable as possible.

    Our clinic has been open for over ten years, and we do over 17,000 treatments a year. We have extensive experience in treating people

    More

    Weich, Erika Organization: Flatirons Acupuncture
    Date: 08/14/2019
    Comment:
    I have been an acupuncturist for 16 years. I find acupuncture extremely effective for low back pain. Please consider adding acupuncture to Medicare coverage, it would be an addition that would help patients and benefit the giver emeet by spending less on these patients as it is possible to get results in just a few treatments.
    Giammarco, Molly Organization: National Certification Commission for Acupuncture and Oriental M
    Date: 08/14/2019
    Comment:

    August 14, 2019

    Tamara Syrek Jensen, JD
    Director, Coverage and Analysis Group
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    Dear Ms. Syrek Jensen and Colleagues:

    The National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) appreciates the opportunity to provide comments to the Centers for Medicare and Medicaid Services’ (CMS) Proposed Decision Memo for Acupuncture for

    More

    Millett, Carolyn Title: Reimbursement and Regulatory Affairs Sn Mgr
    Organization: AAPM&R
    Date: 08/14/2019
    Comment:
    The American Academy of Physical Medicine & Rehabilitation (AAPM&R) appreciates this opportunity to comment on the National Coverage Analysis and Proposed Decision Memo on Acupuncture for Chronic Low Back Pain. AAPM&R supports the proposal to cover acupuncture provided to Medicare patients with chronic low back pain in clinical trials supported by the National Institutes of Health or CMS approved studies meeting AHRQ criteria. In the AAPM&R Position Statement on Opioid Prescribing available

    More

    Jacob, Allison Organization: VTAA
    Date: 08/14/2019
    Comment:

    This is an important study to potentially help millions of people with a non-pharmaceutical option for pain care. It is imperative that the proper persons, Licensed Acupuncturists perform the acupuncture. This kind of language would be ideal:

    Licensed Acupuncturists or state equivalents who carry an active and unrestricted license in the state of practice may provide acupuncture.

    As well, While I understand the need for direct supervision by a physician during trial

    More

    Kenny, Bonnie Organization: Ms
    Date: 08/14/2019
    Comment:

    request is that the language of the proposed be updated:

    • to include‘licensed acupuncturists’
    • and remove physician assistants, nurse practitioners/clinical nurse specialists, and auxiliary personnel, since acupuncture/dry needling are not within their scopes of practice.

    Furthermore, it is appropriate to remove requirements for physician supervision. Acupuncture is a licensed profession that is regulated by legislation in 48 states and the District

    More

    Thompson, Dr. Kimberly Title: DACM
    Date: 08/14/2019
    Comment:
    I am in absolute favor for including acupuncture for low back pain in the medicare coverage program. I treat low back pain in my acupuncture clinic on a daily basis with great success. Nothing brings me more joy than to help someone who is in pain to lead a healthy productive life without the need pain meds and the side effects that ensue.
    Fang, Yaohui Title: Licensed Acupuncturist, CA
    Organization: Guangzhou Acupuncture and Herbs
    Date: 08/14/2019
    Comment:

    August 14, 2019

    Dear Dr. Miller and Mr. Dolan:

    I commend the efforts by CMS to study the effects of acupuncture for chronic low back pain in populations covered by Medicare. I would like to thank the CMS for its consideration of this topic which represents an important step towards the incorporation of acupuncture into national health care.

    California licensees represent nearly one-third of all licensed acupuncturists in the USA. Along with other relevant

    More

    CHANG, KAREN Title: ADS
    Date: 08/14/2019
    Comment:

    I have worked with many cases of chronic low back pain at an acupuncture clinic and also at a massage spa. Acupuncture can help relieve the pain, as well as Tuina massage and decompression therapy. Many senior patients come for a combo treatment at our clinic for low back pain with acupuncture and Tuina. I also see many clients at the spa with low back pain and I treat them with massage and decompression therapy. My experience tells me that seniors prefer the touch aspect, so even though

    More

    hung, alex Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Barili, Margaret Title: RN, LAc, Dipl.Ac
    Organization: Connecticut Society of Acupuncturists (CTSA)
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    August 14, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)
    Dear Dr. Miller and Mr. Dolan,

    The Connecticut Society of Acupuncturists – (CTSA) is an organization representing 411 Connecticut licensed acupuncturists and is a member of the national organization, the American Society of

    More

    Belanger, Michelle Title: Acupuncture Physician
    Organization: FSOMA
    Date: 08/14/2019
    Comment:
    Thank you for moving forward with an inclusion of acupuncture. I am unsure about the omission of acupuncturists in the studies as we are using this medicine daily and have experience that is useful for the progression of our health care. I see daily successes with this medicine in regards to pain and chronic pain so I am happy to see that there is a movement toward inclusion.
    Drozd, Ryan Date: 08/14/2019
    Comment:
    I believe that individuals with chronic low back pain, or any chronic pain condition deserve the opportunity to access therapies that may reduce their pain levels and enhance their quality of life. It's worth providing coverage for all Medicare beneficiaries living with chronic low back pain or chronic pain in general, not just those enrolled within an approved study. [PHI Redacted]
    Falardeau, John Title: Sr. Vice President
    Organization: American Chiropractic Association
    Date: 08/14/2019
    Comment:

    August 14, 2019

    Ms. Seema Verma
    Administrator
    Centers for Medicare & Medicaid Services
    U.S. Department of Health and Human Services
    P.O. Box 8016
    Baltimore, Maryland 21244-8016
    RE: Proposed Decision Memorandum for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Administrator Verma:

    The American Chiropractic Association (ACA) appreciates the opportunity to comment on the Proposed Decision Memorandum

    More

    Byrne, Therese Organization: Happy Sunflower Acupuncture
    Date: 08/14/2019
    Comment:
    Dear CMS, Thank you for your consideration on this topic. This is a big step towards better health for many people. I ask that the section which includes "auxiliary providers" be changed to clearly state "Licensed Acupuncturists or state equivalent". As an acupuncturist I was required to finish my undergraduate degree in premed in order to get accepted into acupuncture school which was another 3 years, year round, of training specifically on acupuncture. I received extensive training in

    More

    Bang, Vincent Title: Onwer/Acupuncturist
    Organization: Byuck San Acupuncture Clinic
    Date: 08/14/2019
    Comment:
    None
    Rodriguez, Shanell Title: Licensed Acupuncturist
    Organization: People's Organization of Community Acupuncture (POCA)
    Date: 08/14/2019
    Comment:

    I support Medicare/Medicaid Coverage of acupuncture treatments for people who suffer from chronic low back pain.

    I practice acupuncture in a low cost/high volume Community Acupuncture clinic and I have been licensed for 3 years. Low back pain is the most common reason why patients seek acupuncture. Acupuncture is better when used early on and not as a last resort. Acupuncture is safe, effective and completely drug-free.

    Acupuncture can be used on its own or in conjunction

    More

    Lewis, Lisa Title: LAc.
    Organization: Jade Path Studio
    Date: 08/14/2019
    Comment:
    Low back pain is perhaps the si for most commonly treated condition amongst acupuncture offices. We are so lucky to live in a state which offers insurance plans covering this condition for acupuncture treatment. Nearly everybody at some point in their lives deal with low back pain, and it is among the highest ranking reasons why people leave work and go on disability. With the opiate crisis long coming to head, we need to give patient ya safe and healthy alternatives in pain management.

    More

    Weissman, Richard Title: Licensed Acupuncturist in California
    Organization: Acupuncture Wellness of Calaveras
    Date: 08/14/2019
    Comment:
    Since 1999 there have been over 4,000 clinical studies in the US showing acupuncture as effective in treating over 150 complaints and diagnoses. 2017 in Germany was a landmark study for low back pain showing it more effective than "usual care." In my 20 years and 8,000 patients, acupuncture always achieves significant progress in pain relief, anti-inflammatory, and healing. Our schooling is 4,000 hours and then 50 hours CEUs every two years. Beyond that is seeing so many patients each week.

    More

    Mullen Desierto, Kelly Kay Title: Licensed Acupuncturist
    Organization: Aligned Modern Health
    Date: 08/14/2019
    Comment:

    Thank you so much for studying the effects of acupuncture on low back pain! As an acupuncturist, I clearly see the benefits of acupuncture for eldery individuals experiencing chronic pain, and it would help this population so much to have Medicare coverage.

    I would like to request that Licensed Acupuncturists specifically be listed as approved providers, as we have the most extensive training in acupuncture itself (class hours and internship hours) as compared to PTs,

    More

    WANG, HONGJIANG Date: 08/14/2019
    Comment:
    ACUPUNCTURE IS VERY GOOD FOR CHRONIC LOW BACK PAIN. IT COULD RELIEVE LOCAL MUSCLE TENSION AND HELP CIRCULATION.
    Masferrer, Roberto Date: 08/14/2019
    Comment:

    I am pleased to hear that CMS is considering covering acupuncture in the future, as I am sure many of my patients who are currently on Medicare and having to pay out of pocket for treatment will be. However, I am concerned about the wording in the proposal. I believe Licensed Acupuncturists and not PAs or NPs should be listed and agree with the wording proposed by the American Society of Acupuncturists, which states as follows.

    Licensed Acupuncturists or state equivalents who carry an

    More

    Lamarhe, Michele Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:

    Please note that physicians assistants, nurses and nurse practitioners have no more hours of study for licensing than do acupuncturists. In California, acupuncturists complete current educational requirement of 3,000 hours of didactic and clinical training. Additionally, I strongly object to the term “auxiliary personnel” as the default term for licensed acupuncturists, who have obtained the unique Bureau of Labor Statistics (BLS) designation 29-1199.01 Acupuncturist, especially since we

    More

    Kinnane, Dr Dennis Title: Licensed Acupuncturist, Reg Pharmacist
    Organization: Cal ATMA, American Society of Acupuncturists
    Date: 08/14/2019
    Comment:
    I have been a Licensed Acuouncturist in California since 1988 and a Registered Pharmacist since 1969. I applaud the belated investigation of acupuncture for back pain by the CMS and can personally attest to the effectiveness thereof. I have reviewed the guidelines for the proposed study and agree wholeheartedly with the critique sent by the Board of Directors of CalATMA and the ASA. It is time that our national government entities recognize the stature which the acupuncture profession has

    More

    Monin, Jennifer Title: Acupuncturist LAc
    Organization: Jennifer Monin Acupuncture
    Date: 08/14/2019
    Comment:
    I am a liscenced acupuncturist in California and belong to CSOMA.
    I want all acupuncturists to be included in this study.
    I want recognition of the California Acupuncture Licensing exam to be equivalent of NCCAOM exam for purposes of this study.
    I want licensed acupuncturists to be recognized as independent practitioners without the need for supervision by physician assistants, nurse practitioners and / or clinical nurse specialists.
    Retherford, Martin Title: Doctor
    Date: 08/14/2019
    Comment:
    There are documented measurable cytological effects for acupuncture including chemokines, interleukins, and hormonal effects. Quantitative research will afford the ability to help prevent and treat opioid use disorder, primarily triggered by low back pain. Acupuncture coming to a facility near you.
    Gallentine, Leesa Title: Ms
    Date: 08/14/2019
    Comment:

    The Centers for Medicare and Medicaid Services (CMS) absolutely must do the proper due diligence regarding the pending federal study of acupuncture for chronic low back pain. This means including ALL licensed acupuncturists in the study and recognizing them as independent practitioners with no need of "supervision" by western medicine. It also means excluding other practitioners who are not licensed acupuncturists but who incorporate the (IMO) questionable and dangerous practice of "dry

    More

    Maggio, Gerard Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    As a Member of the Acupuncture Society of New York (ASNY) and the American Society of Acupuncturists, I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in

    More

    Hawker, Tamryn Title: Mrs
    Organization: Artemisia Acupuncture + Apothecary
    Date: 08/14/2019
    Comment:

    To Whom It May Concern,

    Thank you for considering this study to assess acupuncture as an option for our medicare members suffering from chronic lower back pain.

    I would like to express my concern over some of the proposals mentioned in the decision memo. I am a California State Licensed Acupuncturist with over 3000 hours of clinical training and am confused as to why acupuncturists with my extensive training are not mentioned as being able to participate in this study

    More

    Cohen, Yaron Title: Licensed Acupuncturist, Diplomate of Oriental Med
    Organization: Wise Wellness, Kensington, MD
    Date: 08/14/2019
    Comment:

    First of all I would like to thank CMS for consideration of this topic. Acupuncture and Chinese medicine, when performed properly, will revolutionize the practice of medicine in the United States. I must emphasize the proper performance of acupuncture and Chinese medicine because this is a significant factor in determining the efficacy of a therapeutic modality. For example, while acupuncture and dry needling are essentially identical modalities, acupuncturists have the proper theoretical

    More

    Lear, Daisy Title: President
    Organization: Private Practice and 501c3 Acupuncture for Veterans & Families
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    To Everyone Working Very Hard to Provide Acupuncture :

    Acupuncturists and recipients of Medicare applaud efforts by CMS to study the effects of acupuncture for chronic low back pain in populations covered by Medicare. I have been licensed to practice Chinese medicine and acupuncture since September of 2001. Over the years, many people with

    More

    Rogers, Christopher Title: Acupuncturist
    Organization: People's Organization of Community Acupuncture (POCA)
    Date: 08/14/2019
    Comment:

    I'm an acupuncturist at Wasatch Community Acupuncture, a large non-profit clinic that offers acupuncture on a $15-$40 sliding scale. We are members of the national cooperative called the People's Organization of Community Acupuncture (POCA), that is committed to making acupuncture as accessible and affordable as possible. I've had nine years experience treating people with chronic low back pain. As with any medicine acupuncture doesn't work 100% of the time but it works much of the time and

    More

    Fernandez, Maria D Title: Student
    Organization: Alhambra Medical University
    Date: 08/14/2019
    Comment:
    Hello, I would kindly ask you to visit an Oriental Medicine college and notice what Asian Medicine students need to learn in order to practice on patients. Perhaps you might even want to get treated at our clinic: Before going solo to treat patients I have to pass several location, theory & techniques. In California I need to pass the California licensing exam to practice here. If I want to practice anywhere else in the county, I need to pay additional fees and pass the national exam. I

    More

    Mallon, Jessica Date: 08/14/2019
    Comment:

    [PHI Redacted] I want to thank the CMS for your consideration of this important topic if adding acupuncture to Medicare so more Americans can receive it's benefits.

    However, in reading how the CMS proposes to investigate acupuncture here are a few recommendations:

    1. The section that includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent”. The qualifications for auxiliary providers exactly describe

      More

    Jung, Kwangmi Title: L.Ac
    Organization: CalAtma
    Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Yu, Jenny Title: L.Ac.
    Organization: SCUHS
    Date: 08/14/2019
    Comment:

    To CMS:
    1) Thank you for your consideration of this important and necessary topic for our national health care.
    2) Please change the section indicating the inclusion of "auxiliary providers" to "Licensed Acupuncturists or state equivalent." It is extremely important for the treatments to be administered by trained and licensed acupuncturists, for the safety of patients (for example: SCUHS (Southern California University of Health Sciences) is a non-profit and regionally, state,

    More

    Choi, Elisabeth Title: California licensed acupuncturist
    Organization: Evolve Integrative Health
    Date: 08/14/2019
    Comment:

    The CA board of acupuncture is parallel if not more rigorous than the NCCAOM and California licensee acupuncturists (L.Ac.) have reciprocity with NCCAOM that it does not make sense to exclude L.Ac’s.

    U.S acupuncture programs range from masters to doctorate programs that include fundamental basics of anatomy, physiology, biology and chemistry like any other health profession such as physicians assistant or nursing. Acupuncturists are licensed to have the clinical autonomy of

    More

    Kim, You Title: Acupuncturist
    Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this studyWe want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Lenssen, Henriette Organization: The Acupuncture Room
    Date: 08/14/2019
    Comment:

    Dear,

    I am a member of CalATMA
    Licensed Acupuncturists need to be included in this study because of their superior training and experience.
    Licensed Acupuncturists are Primary Care Providers in the State of California, we are trained as independent providers.

    Thank you,

    Henriette Lenssen L.Ac.
    Lemieux, Jason Title: Director of Government Affairs
    Organization: Center for Inquiry
    Date: 08/14/2019
    Comment:

    The Center for Inquiry (CFI) appreciates this opportunity to comment on the proposed decision memo, Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N).

    CFI Is a Charitable Nonprofit Organization Dedicated to Advancing Evidence-Based Policy.
    CFI is an educational and advocacy organization that promotes reason and scientific integrity in public affairs. CFI’s vision is a world where people value evidence and critical thinking, where superstition and

    More

    Hill, Catherine Title: Senior Manager, Regulatory Affairs
    Organization: AANS/CNS
    Date: 08/14/2019
    Comment:

    On behalf of the American Association of Neurological Surgeons and the Congress of Neurological Surgeons, we appreciate the opportunity to submit our comments regarding proposed coverage for acupuncture for chronic low back pain (CAG-00452N)

    August 14, 2019

    Tamara Syrek Jensen, Esq.
    Director, Coverage and Analysis Group
    Office of Clinical Standards and Quality
    Centers for Medicare & Medicaid Services
    7500 Security Blvd.
    Baltimore, MD

    More

    Tsai, Ken Date: 08/14/2019
    Comment:
    I am licensed acupuncturist and practice in California since 1983. I have provided excellent service for many patients during the past 36 years.
    The chronic lower back pain is one of the condition that response very well with acupuncture. The licensed acupuncturist is the expert on this field not "auxiliary personnel", and well better than supervision of acupuncturists by physician assistants, nurse practitioners and/or clinical nurse specialists. The study should include California

    More

    Spetnagel, Liz Title: President
    Organization: Acupuncture Association of Colorado
    Date: 08/14/2019
    Comment:

    As a licensed acupuncturist for nealrly 20 years, I know how useful acupuncture is in cases of CLBP among other complaints. While I am excited about the move towards the expansion of acupuncture into the Medicare/Medicaid systems, I am concerned with the language of the Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N). As it is currently written, it threatens to obstruct significant numbers of licensed acupuncturists from participating in current and future

    More

    Brittenham, Jennifer Title: L.Ac.
    Organization: Southwest Integrative Wellness Center
    Date: 08/14/2019
    Comment:

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    I am so grateful for the efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a Licensed Acupuncturist (L.Ac.) I want to seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below: Physician assistants, nurse

    More

    Chang, Kyo Title: L.AC
    Organization: Shin Acupuncture and Herbs
    Date: 08/14/2019
    Comment:
    I am a licensed acupuncturist of Acupuncture Board of California. Acupuncture treatment is not just a needle puncturing skin action. Needling is a last step after full consultation based on meridian therapy for presenting symptoms. To deliver safe and effective acupuncture treatment for patient acupuncture the licensed acupuncturist should be primary provider and should included in the study.
    Rankin, Sara Title: Licensed Acupuncturist
    Organization: Alma Acupuncture
    Date: 08/14/2019
    Comment:
    Hello, I am writing with concerns regarding the proposal for the study on low back pain. I am a member of CSAOM & CalATMA. The study appears to not include acupuncturists licensed by the California Acupuncture Board if they do not hold a certification from NCCAOM as well. I just wanted to say that as an acupuncturist who has been practicing for 16 years, acupuncture is very effective in the treatment of low back pain a majority of the time. I am glad that you are conducting this study. I d

    More

    Simone, Stacey Title: L.Ac., Dipl.Ac.
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    August 14, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    As a Member of the Acupuncture Society of New York (ASNY) and the American Society of Acupuncturists, I applaud efforts by CMS to study the effects of acupuncture for chronic low back

    More

    Gusch, Elene Title: Doctor of Oriental Medicine
    Date: 08/14/2019
    Comment:

    Thank you for at last beginning a process of at least studying the incorporation of acupuncture within Medicare coverage. I have been in practice for 23 years, and have been advocating and hoping for this the entire time. My patient base is largely over 60, with some in their 80s and 90s. Their income tends to be limited, and insurance coverage is crucial.

    No matter how you go about this process, the thing to keep in mind is that acupuncture is a huge help to the health and

    More

    Durst, Lanelle Title: L.Ac.
    Date: 08/14/2019
    Comment:
    I am a member of CalATMA . We want all licensed acupuncturists to be included explicitly in this study due to their superior training and experience.
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study. We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Thank you.
    Phelps, Scott Date: 08/14/2019
    Comment:

    The proposed document would allow certain non-acupuncturists to provide acupuncture services. I believe this this should define their credentials beyond NCCAOM and should be within their scope in the state they are practicing, and in the case of California, have the equivalent of NCCAOM certification according to state regulations. In Caifornia's instance, their examination is called the CALE and is equivalent, if not more strenuous and comprehensive, than the NCCAOM. This proposal excludes

    More

    Spitzner Claussen, Alice Date: 08/14/2019
    Comment:
    Thank you for considering acupuncture for coverage for chronic low back pain. Acupuncture has a long history of relieving pain in a safe and effective manner. It would be a great service to make this treatment accessible to the populations needing it the most. In order to have the best possible outcomes it is important to have well trained providers. In my state of Iowa Licensed Acupuncturists (LAc) are far and away the most highly trained providers of acupuncture. LAcs in Iowa are

    More

    Berry Swadell, Megan Title: Licensed Acupuncturist
    Organization: CalATMA
    Date: 08/14/2019
    Comment:
  • I want all licensed acupuncturists to be included in this study
  • I want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
  • I want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
  • Wu, Julia Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:

    While it is strongly commendable that this study is trying to prove the efficacy of Acupuncture for chronic low back pain, the exclusion of Licensed and Board Certified Acupuncturists from the primary investigator positions and allowing non-licensed persons to perform Acupuncture instead is not only insulting to the Acupuncture profession at large, it will also undermine the efficacy of your study.

    Only licensed Acupuncturists have the full knowledge and experience to impart as

    More

    Alvarez, Edwin Title: Acupuncturist
    Organization: ILAOM
    Date: 08/14/2019
    Comment:
    Thank you CME, for bringing the attention to this important cause. I look forward to seeing the supervision and the use of auxiliary practitioners and alternative care providers, especially that of acupuncturist in caring for people with low back pain. Here in Illinois we require that practitioners of acupuncture have 3 and half years of training, be nationally certified as well as be licensed. I look forward to standards of practice as well as supervision during this trial basis. I also look

    More

    Ducos, Valerie Organization: Valerie Ducos L.Ac.
    Date: 08/14/2019
    Comment:
    I have been treating back pain with acupuncture with excellent results for 16 years. As a California trained and licensed acupuncturist I take health insurance which alows many people who would not be able to afford treatment to get relief.
    Western medicine's only option is surgery, cortisone shot or drugs.This does not work or is a temporary fix in at least 75% of patients. Since Medicare does not cover the cost.of acupuncture the elderly population are often left untreated and in

    More

    Werner, Alison Title: Acupuncturist
    Organization: Wood Rabbit Acupuncture, LLC
    Date: 08/14/2019
    Comment:

    Dear CMS,
    Thank you for considering including acupuncture in Medicare.

    I am asking that you change the section that includes “auxiliary providers” to be changed to more clearly name “Licensed Acupuncturists or the state equivalent”. The qualifications for auxiliary providers exactly describes this licensure group.

    As a certified acupuncturist in Wisconsin, I hold a Masters of Science in Traditional Chinese Medicine. I needed over 1,000 hours of training and

    More

    Bolash, Bonnie Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:

    RE: Policy coverage of acupuncture for Chronic Low Back pain

    Thank you for the opportunity to reply with comments on acupuncture for chronic low back pain. I really wanted to comment before you created your draft proposal. I will just put my comments in sections that you can use to discuss the policy decision on the coverage of acupuncture for chronic low back pain.

    Acupuncturists in Minnesota
    Acupuncturists are a new profession. Minnesota requires those that

    More

    Nelson-Hicks, Stace Title: Doctor of Acupuncture and Chinese Medicine
    Organization: CalATMA
    Date: 08/14/2019
    Comment:
    I agree whole heartedly with CalATMA’s statement. Other than being supervised for this study, there is no need in any state for an L.Ac. Or DACM to be supervised. With licensed acupuncturists, not under trained auxiliary practitioners, safety risk is negligible. In California we are considered primary care providers.
    Narayan, Atil Title: Doctor of Acupuncture and Chinese Medicine
    Organization: Natural Wonders Healthcare
    Date: 08/14/2019
    Comment:

    Hello,

    Your proposed document would allow certain non-acupuncturists to provide acupuncture services. Non acupuncturist do not have the level of training of licensed acupuncturists, particularly in the state of California where the standards are quite high.

    It excluded California licensed acupuncturists who have not also been certified by the NCCAOM. California licensure is equivalent to the NCCAOM, even by NCCAOM standards.

    It labeled licensed

    More

    Gates, Don Organization: Grand Acupuncture Center
    Date: 08/14/2019
    Comment:

    I write to express my solidarity with the points expressed in the letter of August 4, 2019, by the California Acupuncture and Traditional Medicine Association (CalATMA) regarding the study of the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As the proposal is written:

    The proposed document would allow certain non-acupuncturists to provide acupuncture services,
    It excluded California licensed

    More

    KIM, SOU Date: 08/14/2019
    Comment:
    Licensed acupuncturists need to be included in this study as they have the expertise and superior training to determine necessary diagnostic and treatment protocols
    Grudi, Karisa Title: Licensed Acupuncturist and co-owner
    Organization: NCCAOM, ASA
    Date: 08/14/2019
    Comment:
    Acupuncture has a long history (+4000 yrs) of treating chronic pain especially low back pain. Virtually all of my patients have experienced a need for pain management. Within 8-10 treatments, most symptoms have subsided or completely resolved. Within our practice, we have approx 40% of patients on Medicare. To include acupuncture coverage in their plans would mean greater relief and benefit for them. Please consider adding acupuncture benefits for Medicare patients.
    Clifford, Cristina Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:
    • We want all licensed acupuncturists to be included in this study
    • We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    • We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Whitelaw, Andrew Title: LAc
    Organization: Independent Acupuncturist
    Date: 08/14/2019
    Comment:

    I work entirely with insurance patients. Because these companies have determined the limited scope of conditions they deem acupuncture useful for, I treat neck and backpain, often chronic, every day. I use bio-mechanical principles to address muscle imbalance and misfiring muscles that restrict range of motion and create pain feedback loops to the brain. Some patients are relieved immediately. But I treat quite a few who will never be without pain, and have been on heavy opioids,

    More

    Smith, Shaina Title: Director of State Advocacy & Alliance Development
    Organization: U.S. Pain Foundation
    Date: 08/14/2019
    Comment:

    August 14, 2019
    The Honorable Seema Verma
    Administrator, Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    RE: U.S. Pain Foundation Supports Proposed Decision Demo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Administrator Verma,

    The U.S. Pain Foundation is a 501(3)(c) nonprofit organization that seeks to empower, educate, support, and advocate for the 50 million Americans who live with chronic pain. We

    More

    Booth, Beata Title: Licensed Acupuncturist
    Organization: Coast Acupuncture
    Date: 08/14/2019
    Comment:

    California has among the most rigorous acupuncture training in the US, and the board exam is acknowledged to be the most difficult, with the lowest pass rates. Please allow California licensed acupuncturists to treat chronic low back pain.

    Thankyou.

    Beata Booth MTOM, LAc

    Lauren-Kon, Stacy Title: Licensed Acupuncturist
    Organization: Mend Family Acupuncture and Healthcare
    Date: 08/14/2019
    Comment:
    You MUST include the verbiage "By Licensed Acupuncturist"!!! If not, you open the door to unqualified people being included in your study and potentially harming patients.
    Kim, Jung Title: DAOM, L.Ac.
    Organization: Living Acupuncture
    Date: 08/14/2019
    Comment:
    Acupuncture has been showing good effectiveness for acute and lower back pain. Tension head ache related cervical related pain has showing superior effectiveness as well based on my experience.Unfortunately, medicare does not accept acupuncture as treatment which limits great benefit of seniors. They have been paying cash for the treatments. I think acupuncture treatment should be covered by CMS as soon as possible. Thank you.
    Hogan, Michael Title: licensed acupuncturist
    Organization: Mr.
    Date: 08/14/2019
    Comment:

    I am writing to urge you to accept the California Acupuncture license as sufficient proof of training to treat a patient using Acupuncture for chronic low back pain. The California Acupunture Board requires thousands of hours of training and their exam is well known for being much more rigorous than the national exam (which isn't sufficient to practice in California) or any other state board.

    Joo, Jae Title: Licensed Acupuncturist
    Date: 08/14/2019
    Comment:
    Through acupuncture treatment, we were able to assist people wean off of their back brace and pain medications.
    Natrin, Nicolette Title: Student of Chinese Medicine
    Organization: CalATMA
    Date: 08/14/2019
    Comment:

    Hello,

    CMS proposes to study acupuncture for chronic low back pain, but DOES NOT MENTION Licensed Acupuncturists explicitly.

    Here's a summary of my main concerns:

    • The proposed document would allow certain non-acupuncturists to provide acupuncture services,
    • It excludes California licensed acupuncturists who have not also been certified by the NCCAOM,
    • It labels licensed acupuncturists as "auxiliary personnel", and
    • It initiates

      More

    Lizée, Theodore Date: 08/14/2019
    Comment:
    I am a graduate from Emperor’s College of Traditional Oriental Medicine in Santa Monica, California and am participating in the public comment period for this study. We want all licensed acupuncturists to be included in this study. We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study. We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician

    More

    Markland, Shannon Title: Licensed Acupuncturist
    Organization: Markland Acupuncture LLC
    Date: 08/14/2019
    Comment:
    Thank you for the work you are doing to bring acupuncture into the national health care conversation.
    I am writing to ask that the section that includes "auxiliary providers" be changed to more clearly name "Licensed Acupuncturists or state equivalent." In Florida, we have 2700+ hours of training with 600 hours supervised training in the clinic. In Florida, we are considered primary care healthcare providers.
    I also ask that supervision of the study portion be performed only by

    More

    Bock, David Title: Acupuncturist
    Organization: Bock Acupuncture and Herbal Medicine
    Date: 08/14/2019
    Comment:
    As a Medical practitioner who has provided acupuncture services to the VA medical system patients for many years, often treating low back pain, It is welcoming to see that a medical treatment that is seen as beneficial to our VA medical system might be available to more people. The VA recognizes that veterans deserve acupuncture treatment from the most qualified practitioners- people who specialize in acupuncture and have the training and certification to provide that medical service. Please

    More

    Dunnigan, Colleen Organization: Towson Acupuncture Associates
    Date: 08/14/2019
    Comment:

    Thank you for taking the time to hear our thoughts about acupuncture. As an Office Manager of an acupuncture practice, I see copious amounts of senior citizens who want to get acupuncture desperately but cannot afford it. We have kept so many patients from needing surgery just with acupuncture. If you look at the reimbursement that Carefirst pays, 15 visits would cost the insurance company $1188.75 vs the $50-1000k it costs for the surgery. By offering acupuncture, it will save Medicare

    More

    Panettiere, Anna Title: Doctor of Acupuncture and Chinese medicine
    Organization: Anna Panettiere, Acupuncture and Herbs
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    As a Member of the Acupuncture Society of New York (ASNY) and the American Society of Acupuncturists, I applaud efforts by CMS to study the effects of acupuncture for chronic low back

    More

    McDowell, Meg Title: Acupuncturist
    Date: 08/14/2019
    Comment:
    In response to the study to be done, it is disrespectful to and devaluing of acupuncturists to label them "auxilliary". Additionally including nurses, doctors and physical therapists who usually have sub par education in Traditional Chinese Medicine, and don't have to do the required continuing education, deflates the quality of the study. Please use only licensed acupuncturists in this study and call them such.
    We have worked long and hard and continue to do so to keep our profession

    More

    Berry, Kate Organization: AHIP
    Date: 08/14/2019
    Comment:

    America’s Health Insurance Plans (AHIP) appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) national coverage analysis for acupuncture for chronic low back pain.

    AHIP is the national association whose members provide coverage for health care and related services. Through these offerings, we improve and protect the health and financial security of consumers, families, businesses, communities and the nation. We are committed to market-based

    More

    Roberts, Julian Title: Executive Director
    Organization: National Association of Specialty Health Organization (NASHO)
    Date: 08/14/2019
    Comment:

    The Physical Medicine Management Alliance (PMMA) of the National Association of Specialty Health Organization (NASHO) appreciates the opportunity to comment on Proposed Decision Memo on Acupuncture for Chronic Low Back Pain.

    NASHO is one of the nation’s only organizations solely focused on fully integrating specialty health into the healthcare reimbursement model. PMMA’s mission is to promote the value of physical medicine and integrative healthcare in generating quality outcomes

    More

    Choi, Yoonho Date: 08/14/2019
    Comment:

    Hello,

    1. I want all licensed acupuncturists to be included in this study
    2. I want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    3. I want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists

    Thank you.

    Mager, Amy E Title: Chair, Acupuncture Society MA
    Organization: Acupuncture Society MA
    Date: 08/14/2019
    Comment:

    14, August, 2019

    The Acupuncture Society of MA would like to thank the CMS for your consideration of this topic. It is important that a health care service used by so may patients that is provided by Licensed acupuncturists who have been trained, vetted and licensed to practice be able to provide the service they have trained for many years, typically 6-8 to provide care for patients.

    To practice acupuncture in MA one must have at least 60 hours of undergraduate education

    More

    Vincent, Ellen Title: Director
    Organization: Backyard Healthcare Project
    Date: 08/14/2019
    Comment:

    I support Medicare/Medicaid Coverage of acupuncture treatments for people who suffer from chronic low back pain.

    Like many of my colleagues, I practice acupuncture in a low cost/high volume Community Acupuncture clinic and I have been licensed for 13 years. Low back pain is hands-down the most common reason why patients seek acupuncture, and these patients constitute a majority of our entire patient base. I always tell them "If we couldn't treat low back pain, we'd be out of

    More

    Shan, Zhiyin Organization: Mental Wellness Acupuncture
    Date: 08/14/2019
    Comment:
    Acupuncture really helpful for chronic low back pain. In my clinic almost 30% patient has chronic low back pain. Acupuncture use needles to stimulate nerves make muscle relax and no side effect. Acupuncture is cheaper and more safety than surgery. I suggest before surgery the patient should try acupuncture first, it will save much more coast than surgery. If there is any research program to compare acupuncture and surgery, I will like to join the research.
    LeBlanc, Greg Date: 08/14/2019
    Comment:

    I am member of CalATMA, we have these concerns:

    We do not know the concern(s) that led CMS to not explicitly mention licensed acupuncturists as personnel permitted to furnish acupuncture in these trials. We offer the following information, in the hopes that it will help address whatever the concern(s) might be:

    The requirements for licensure and bi-annual recertification are essentially identical to all other health we request that CMS revise the Proposed Decision Memo

    More

    Luo, LuGuang Title: Assistant Professor, Director, MD.,PhD. LAc and DA
    Organization: The Center for Natural Healing Rhode Island
    Date: 08/14/2019
    Comment:
    Acupuncture for acute or chronic low back pain has high effective positive results which can prevent acute problems become chronic and avoid consequences of chronic low back pain generate suffering and other over dosage of painkiller application. It has not only affect for disorder treatment but also facilitate the effects of medication.
    Chischilly, Leah Date: 08/14/2019
    Comment:
    I have worked as an acupuncturist for five years and am involved with a company that has acupuncture clinic locations across the country. We recently surveyed our patients and low back pain is the number one reason people are seeking out acupuncture care. Acupuncture is a risk-free and effective approach to treating back pain without the use of medication or surgery. It provides people with more affordable options, zero downtime and has benefits beyond just pain relief.
    Fan, Jeremiah Date: 08/14/2019
    Comment:

    As a Member of the Association for Professional Acupuncture in Pennsylvania and the American Society of Acupuncturists, I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As my colleagues in the Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently

    More

    Nord Parish, Briana Title: Manager, Federal Government Affairs
    Organization: Allina Health
    Date: 08/14/2019
    Comment:

    August 14, 2019

    Dr. Susan Miller
    Mr. David Dolan
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    To Dr. Miller and Mr. Dolan,

    On behalf of Allina Health and its Penny George Institute for Health and Healing, I want to thank the Centers for Medicare and Medicaid Services (CMS) for its further interest in the effects of acupuncture to treat chronic low back pain in populations covered by Medicare and appreciate

    More

    Shin, Dong Date: 08/14/2019
    Comment:
    Acupuncture really works with lower back pain!!
    Kwak, Daniel Title: Owner
    Organization: Star Acupuncture
    Date: 08/14/2019
    Comment:
    When it comes to Chronic Low Back Pain Treatment, Acupuncture is the best as many people know it.
    Ganel, Grace Title: L.Ac.
    Organization: Three Treasures Wellness LLC. Maryland Acupuncture Society. ASA.
    Date: 08/14/2019
    Comment:

    As an acupuncturist in America, I believe that access to acupuncture should be possible for as many Americans as desire it. Therefore I applaud CMS's determination to explore acupuncture for low back pain in the population served by Medicare. I urge you to heed the suggestions of ASA regarding the language in your proposed research. Rather than "Physicians assistants...," I implore you to use the language: "Licensed Acupuncturists or state equivalents who carry an active and unrestricted

    More

    Tuan, Zen Title: Licensed acupuncturist
    Organization: Healing with Zen
    Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Joe, Sehee Title: L.ac
    Date: 08/14/2019
    Comment:
    We want all licensed acupuncturists to be included in this study
    We want recognition of the California Acupuncture Licensing Exam to be equivalent to the NCCAOM exam for the purposes of this study.
    We want licensed acupuncturists to be recognized as independent practitioners, without the need for supervision by physician assistants, nurse practitioners, and/or clinical nurse specialists
    Quigley, Graham Date: 08/14/2019
    Comment:

    As a CA licensed Acupuncturist, I am very excited about our ability to practice in this arena. However, I strongly believe one should only be required to be CA licensed, and not also the NCCAOM license as well. As someone who sat for both exams, we are grateful to have the CA exam and license that is exceptionally thorough compared to the National accreditation.

    Also, we are capable of practicing as independent medical practitioners, and the idea of requiring supervision by a PA

    More

    Braverman, Carol Date: 08/14/2019
    Comment:

    I am a licensed acupuncturist with an active license in CO and and an inactive license in NY which can be reactivated upon request. My Masters degree inculded 3,000 didactic hours, approximately 1,500 in biomedicine and 1,500 in Traditional Chinese Medicine theory and application. In addition I had 1,000 of clinical training, in the student clinic and in a hospital setting at Lutheran in Brooklyn, NY, now a Langone NYU facility. In NY I worked in a private practice with a pain management

    More

    oh, hyunseog Date: 08/14/2019
    Comment:
    Acupuncture has been used for chronic low back and proven very effective. It should be used for patients as an alternative for pain medications. Thank you.
    Ann, Stephanie Title: Secretary
    Organization: Acupuncture Association of Colorado
    Date: 08/14/2019
    Comment:

    August 13, 2019
    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare and Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    Dear Mr. Dolan & Dr. Miller,

    The Acupuncture Association of Colorado and our licensed acupuncturists thank you for efforts made on behalf of the Centers for Medicare & Medicaid Services (CMS) to study acupuncture for chronic low back pain in Medicare populations.

    We thank you for the

    More

    Krystufek, Viktor Title: President
    Organization: Acupuncture Society of New York
    Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    As a Member of the Acupuncture Society of New York (ASNY) and the American Society of Acupuncturists, I applaud efforts by CMS to study the effects of acupuncture for chronic low back

    More

    Heron, David Title: Doctor Of Acupuncture and Chinese Medicine
    Date: 08/14/2019
    Comment:

    While I applaud your interest in studying the benefits of acupuncture, I believe a few changes need to be made in order to achieve the most accurate results. They are as follows:

    1. Licensed Acupuncturists have the highest level of training in acupuncture and represent the majority of practitioners providing acupuncture in the United States. If you truly want to study the effectiveness of acupuncture it would behoove you to remove the designation of Licensed Acupuncturists

      More

    Burns, Montana Title: Licensed Acupuncturist & Herbalist
    Organization: Atlas Acupuncture
    Date: 08/14/2019
    Comment:

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    I am so grateful for the efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a Licensed Acupuncturist (L.Ac.) and soon to be Doctor of Acupuncture and Chinese Medicine (I currently hold the 4 years Master's degree after my B.S. in Neuroscience for undergraduate studies), I want to seek

    More

    Potter, Brit Title: Mr.
    Organization: Potter Acupuncture
    Date: 08/14/2019
    Comment:
    I live in the Kentucky coal fields. There are many active and retired coal miners and truck drivers that suffer from Low Back Pain! These men and women need help! Acupuncture is a great alternative to opioids. Please add acupuncture coverage so acupuncturist may help those that suffer with Low Back Pain!
    Lin, Jeff Title: Certified acupuncturist
    Organization: CALATMA
    Date: 08/14/2019
    Comment:
    Acupuncture should be perform by certified acupuncturist and have to be study and training by acupuncture school for full 4 years. And after graduate from school should pass acupuncture board exam to get the acupuncture license.
    It is very dangerous and very ineffective if just only few hours training then to perform acupuncture to patients.
    Turczyn, Kathleen Organization: Kat's Flat Art
    Date: 08/14/2019
    Comment:
    Please add licensed acupuncturists to your list of medical providers that CMS covers. Some people are only helped by acupuncture. And why limit coverage to low back pain? Acupuncture has helped migraines and foot pain, in my specific experience.
    Kim, Kyu hwan Date: 08/14/2019
    Comment:
    Yes
    We need to treat chronic lower back pain with madicare plane
    PAO, HAO Date: 08/14/2019
    Comment:
    Licensed acupuncturist should be included in this study.
    Dai, Shujing Date: 08/14/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    As a Member of the Acupuncture Society of New York (ASNY) and the American Society of Acupuncturists, I applaud efforts by CMS to study the effects of acupuncture for chronic low back

    More

    Min-Yau, Dr. Ahnee Min Title: LAc, DACM
    Organization: Tao Natural Healing
    Date: 08/14/2019
    Comment:

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    On behalf of the American Society of Acupuncturists and our 4500 members nationwide, we applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As representatives of the Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the

    More

    Jia, Weihong Date: 08/14/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    Zhao, Jun Yi Date: 08/14/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    Hart, Jr. O.M.D., Patrick 'Dr. Skip' Title: Acupuncture Physician<
    Organization: ASKDRSKIP.COM, PLLC
    Date: 08/14/2019
    Comment:

    Dear Dr. Miller and Mr. Dolan:

    My name is Patrick Hart 'aka Dr. Skip' and I am an O.M.D., Acupuncture Physician practicing in the state of West Virginia, whose training is from the Florida College of Integrative Medicine with Doctor's Residency completed at the Conmaul Integrative Hospital in Seoul S. Korea in 2003. My license was issued in 2003 as well. Thank you for your efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered

    More

    Wang, Quan Date: 08/14/2019
    Comment:

    First, we are grateful to the CMS for conducting a clinic trial investigating acupuncture’s effectiveness to treat chronic low back pain in geriatric patients. We understand the need that federal health care legislators seek further evidence for the effectiveness of acupuncture in order to justify federal coverage with medicare. Despite any previous effective clinical trials involving acupuncture in the past, we understand that it needs to be on their terms and conducted within their system

    More

    Lin, Li Title: L.Ac
    Date: 08/13/2019
    Comment:

    Chronic low back pain usually is caused by inflammation from lumbar disc herniation, bulging disc, stenosis, degeneration, etc. Chronic inflammation will block the energy flow and cause stagnation and affect the nerve system. Acupuncture treatment will help circulation, break down the stagnation and ease the pain from my 14 year's clinical experience.

    One of my client (age 80)has severe lumbar stenosis when she came to see me 3 years ago. She kept Acupuncture treatment every two

    More

    Lau, Michelle Title: L.Ac., O.M.D., President.
    Organization: Council of Acupuncture and Oriental Medicine Associations.
    Date: 08/13/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    August 08, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    On behalf of the Council of Acupuncture and Oriental Medicine Associations- CAOMA and American Alliance of Acupuncture-AAOA, and our members organizations in statewide and nationwide, we appreciate

    More

    Sorensen, Kathleen Title: DOM, Acupuncturist
    Organization: FSOMA
    Date: 08/13/2019
    Comment:
    "auxiliary providers" should be changed to "licensed acupuncturist or state equivalent"
    In Florida licensed acupuncturists have 2700 hours of schooling and 600 hours of supervised clinic practice.
    Alson, Naomi Title: Licensed Acupuncturist and Herbalist
    Organization: Acupuncture Society of Massachusetts
    Date: 08/13/2019
    Comment:

    I am so glad that this is being studied, however, it would be important for acupuncture to be done by highly trained professionals, that is, acupuncturists.

    Every day, I have older patients asking for my help with lower back pain. Many cannot afford the service because it is not covered by Medicare. My VA patients and Mass Health patients have coverage for this condition.
    While it is appropriate for an MD to oversee the studies, there is no precedent for other

    More

    Hinman, Barrie Title: Licensed Acupuncturist
    Organization: Barrington Acupuncture Clinic
    Date: 08/13/2019
    Comment:

    Thank you for considering acupuncture as a medically proven treatment for low back pain. I have witnessed positive results many times over a 10 year period treating low back pain and many other painful conditions with acupuncture.

    In defining "auxilliary personnel" I would respectfully request that this be modified to specifically name "Licensed Acupuncturists or state equivalent" as we have been tested nationally and licensed in our states to perform acupuncture with appropriate

    More

    Shepherd, Peggy Date: 08/13/2019
    Comment:
    Please, oh please, add acupuncture to Medicare covered benefits. I believe it very possibly be a cost-saving benefit by reducing the need for surgery, possibly opioids, etc. for pain.
    weinberg, Sara Title: Licensed Acupuncturist
    Organization: Sara Weinberg, MS, L.Ac Acupuncture & Herbs
    Date: 08/13/2019
    Comment:

    I appreciate CMS's consideration of Acupuncture's efficacy for Chronic Low Back Pain (00452N)

    Please also consider the following points:

    1. Please allow all auxiliary providers to be only Licensed Acupuncturists or the state's equivalent. Please note that in California Acupuncturists are required to have a MS degree or equivalent of a PhD that includes supervised clinic hours before they can even sit for the State Licensure boards. Also note that, in California, only

      More

    Vermilya, Bart Organization: Mr.
    Date: 08/13/2019
    Comment:
    Thank you for considering this topic! I would like to offer the following:
    Please change the section that includes "auxiliary providers" to "licensed Acupuncturists or state equivalent". The qualifications for this group exactly describes this Licensure group. Most states require this as a minimum to be granted licensure as an Acupuncturists.
    The supervision of the act of acupuncture should only be supervised by an MD or DO as there is no precedent and doesn't add any value of

    More

    Blades, Roberta Date: 08/13/2019
    Comment:

    I am writing to encourage CMS to cover acupuncture for chronic low back pain, as well as other chronic pain conditions for all Medicare beneficiaries, not just those enrolled within an approved study.

    I appreciate your decision to hear from the chronic pain community because, for some, acupuncture may be an effective alternative. Researching the history of acupuncture long ago I read about surgery being performed in China with only acupuncture and no anesthesia. This ancient

    More

    Morgan, Jenifer Date: 08/13/2019
    Comment:
    Please establish a policy that ANY ACUPUNCTURE PRACTITIONER WITH A CURRENT VALID LICENSE FROM HIS/HER STATE may provide treatment for chronic low back pain. Supervision by a doctor, PA, or other medical practitioner should NOT be required. [PHI Redacted]
    You, Karen Organization: Ms.
    Date: 08/13/2019
    Comment:

    Thank you CMS for your consideration of this topic. This represents a massive step towards the incorporation of acupuncture into national health care.

    Please modify the section that includes “auxiliary providers” to be changed to more clearly name “Licensed Acupuncturists or state equivalent”. The qualifications for auxiliary providers exactly describe this licensure group. Please require supervision during the study portion be done only by an MD. Supervision by other licensure

    More

    Ozeki, Luriko Date: 08/13/2019
    Comment:

    Thank you CMS for your consideration of this topic. This represents a massive step towards the incorporation of acupuncture into national health care.

    Please includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent”. The qualifications for auxiliary providers exactly describe this licensure group. In California, where I practice, we are required to complete 2,050 curriculum hours and 950 hours of clinical hours. After graduating

    More

    Vhang, Victor Date: 08/13/2019
    Comment:

    TO WHO IT MAY CONCERN:

    All researcher and delegate who are conducting studies of acupuncture, must have a medical background in Chinese medicine rather than Western medicine to understand how it works. Otherwise, the results of the study are unknown, which will undermine the development of acupuncture. If the policy maker is not professional nor supports TCM (Traditional Chinese Medicine), or recognizes the importance of values, or the inability to understand TCM before conducting

    More

    S, L Date: 08/13/2019
    Comment:
    I discovered an acupuncture clinic close by to me this past fall, when also, I needed to go to pain management. I was desperate for pain control. Since then, I get an acupuncture "tune up" every six weeks, or so. I do have chronic low back pain from degenerative disk disease, as well as other conditions (migraine, trigeminal neuralgia, fibromyalgia and arthritis). Trying to be objective about whether or not acupuncture "works", I would have to say that it doesn't always "work" right away, but

    More

    Chan, Jeanny Date: 08/13/2019
    Comment:

    As a Member of the New Jersey Association of Acupuncture and Oriental Medicine (NJAAOM) and the American Society of Acupuncturists (ASA), I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As my colleagues in the Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the

    More

    Pierce, Jeanne Title: Ms.
    Date: 08/13/2019
    Comment:
    I've practiced acupuncture for 20 years and have treated many patients with many different types of medical problems including low back pain and most have benefitted, some a little and many a LOT! Many people have told me that if Medicare, Medicaid and private insurance paid for acupuncture (and other modalities of Traditional Asian Medicine (TAM), they would come more for treatment because they feel it's more effective and safer than drugs or other invasive medical procedures. Also, in my

    More

    Tan, Alexander Title: L.AC.
    Organization: Straight Bamboo
    Date: 08/13/2019
    Comment:

    Thank you for considering Acupuncture for Medicare patients. I'm an ex-engineer that has been doing acupuncture for 20-years and it has been of great benefit to so many people with pain, including the elderly. If you are looking for 'non-pharmaceutical solutions to pain' acupuncture is the best choice.

    I was surprised to see that L.AC.'s are not the first choice. I suggest the standard“auxiliary providers” be changed to more clearly named “Licensed Acupuncturists or state

    More

    Estrada, Della Title: Licensed Acupuncturist
    Date: 08/13/2019
    Comment:

    Dear Dr. Miller, Mr. Dolan

    As a licensed acupuncturist (AZ) for 28 years, it is such welcome news that CMS is proposing to study acupuncture for chronic low pain.

    I have carefully read your proposed document, and would like to focus on two items in particular, and respectfully ask for you to please change some wording in the two areas of focus: there needs to be clarification of importance in some text regarding "auxiliary personnel" who may furnish acupuncture if they

    More

    Shotz, Kimberly Title: NP, RN, LAc
    Organization: Oasis Acupuncture & Integrative Medicine, LLC
    Date: 08/13/2019
    Comment:
    I commend CMS for initiating research program to investigate Acupuncture efficacy for Chronic Low Back Pain. Bravo!! I am both a Nurse Practitioner (22 years) and a Board-certified, Oregon State-Licensed Acupuncturist (8 years) and clearly see the benefit of acupuncture for my patients with chronic pain. I do have concerns re: CMS delineation of WHO may provide acupuncture. I would like to see State-Licensed Acupuncturists clearly listed as valid providers. Additionally, states vary re:

    More

    Ropp, Elizabeth Title: Licensed Acupuncturist
    Organization: Manchester Acupuncture Studio
    Date: 08/13/2019
    Comment:

    I support Medicare/Medicaid Coverage of acupuncture treatments for people who suffer from chronic low back pain.

    I practice acupuncture in a low cost/high volume Community Acupuncture clinic and I have been licensed for 12 years. Low back pain is the most common reason why patients seek acupuncture. Acupuncture is better when used a first line of defense, rather than a last resort. Acupuncture is minimally invasive and side effects are rare.

    Acupuncture can be used on its

    More

    anichini, jane Date: 08/13/2019
    Comment:

    [PHI Redacted] I want to thank the CMS for your consideration of this important topic if adding acupuncture to Medicare so more Americans can receive it's benefits.

    However, in reading how the CMS proposes to investigate acupuncture here are a few recommendations:

    1. The section that includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent”. The qualifications for auxiliary providers exactly

      More

    Wu, Joyce Title: Lac.
    Date: 08/13/2019
    Comment:

    August 11, 2019

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244
    RE: Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Mr. Dolan and Dr. Miller:

    I am a licensed acupuncturist in California and nationally certified by the NCCAOM diplomate in Oriental Medicine. I practice in San Francisco. I am also a member of CalATMA. Thank you for requesting comments regarding efforts

    More

    Morales, JuanMorales Title: Lic Ac.
    Organization: The Integrative Health Solution.
    Date: 08/13/2019
    Comment:
    The section that includes "auxiliary providers"be changed to more clearly name “Licensed Acupuncturists or state equivalent” In Florida we have 2700+ hours of training with 600 hours supervised in the clinic. We are considered primary care healthcare providers.
    yoo, sahng Date: 08/13/2019
    Comment:
    Acupuncture is very effective on low back pain. So medicare shuould include benefit of treatment. I highly recommend.
    DePaula, Geoffrey Title: Dr.
    Organization: Root & Branch Oriental Medicine
    Date: 08/13/2019
    Comment:
    As a Doctor of Acupuncture and a licensed health insurance producer I have seen first hand the outcomes of acupuncture and costs related to NOT having acupuncture as a covered benefit. If CMS wants to ACTUALLY SAVE MONEY they should cover acupuncture for many conditions, not just the obvious low back pain which any licensed acupuncturist who has been to an accredited school will tell you is "right up our alley" as far as treatment and effectiveness. One avoided spinal surgery will save CMS

    More

    Toy, Lucinda Title: Acupuncturist
    Date: 08/13/2019
    Comment:

    Dear Dr. Susan Miller and Mr. David Dolan,

    My name is Lucinda Toy; I have been a Licensed Acupuncturist in California since 2009. Thank you for the opportunity to comment to and for your consideration of my thoughts to the Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N).

    I am pleased to learn that CMS is embarking on a proposal to study acupuncture for chronic low back pain. Acupuncture stands as one of the most promising options for

    More

    Baktashian, Arezu Title: General Manager
    Organization: Masuda Acupuncture
    Date: 08/13/2019
    Comment:

    Hello, we have received over 50 calls in the last two years from people with Medicare interested in acupuncture for back, shoulder, and neck pain. These people are interested in trying acupuncture because nothing else has worked for them. Many of whom received positive feedback from others who found relief from acupuncture through our clinic or another practitioner.

    Our clinic is interested in participating in this study. We are an hour away from Sacramento, CA, in El Dorado

    More

    Lee, Johnson Date: 08/13/2019
    Comment:

    Acupuncture is working well with chronic lower back pain.

    As medical doctor graduated at 1988. I was surgeon working in china hospital. Orthopedic surgeon, lower chronic back pain related to almost all the human's life. result is pain in lower back and tighten on back mobility. western treatment is using pain medication which block pain feeling go to brain. It could working well to easy the lower back pain by block them.
    Acupuncture is working more direct on the pain &

    More

    Lee, Angela Date: 08/13/2019
    Comment:
    I am a member of the California Acupuncture and Traditional Medicine Association (CalATMA) and follow their recommendations from their letter send on August 4th. As a current student in this medicine, it is imperative that we listen to the professionals who have decades of experience in this space.
    Ballinger, Lexy Date: 08/13/2019
    Comment:
    Please change the "auxillary providers" to the state equivalent of Licensed Acupuncturist. We have a 5 year Master degree in Oriental Medicine that includes 2700 hours of training and 600 clinic hours. We are primary care healthcare providers and should be explicitly included.
    Thank you
    Kristol, Bruce Title: Clinical Psychologist
    Organization: Kristol Healing Center
    Date: 08/13/2019
    Comment:
    I encourage CMS and Medicare to proceed post haste with this study. Many patients will benefit, I believe. I am a Clinical Psychologist and support Acupuncture modalities.
    Schultz, Kate Date: 08/13/2019
    Comment:
    Please cover acupuncture for lower back pain. Many people don't get help from traditional means. These "alternative" treatments are the only hope some people have of experiencing relief. An initial acupuncture appointment can cost anywhere for $50 to $100 with follow-up treatments costing between $50 and $80. This is much cheaper than joint injections, surgeries, and some medications. Most people using Medicare cannot afford treatments like acupuncture or massage and desperately need it

    More

    Braun, Alix Title: Regulatory Advocacy Specialist
    Organization: American Academy of Orthopaedic Surgeons
    Date: 08/13/2019
    Comment:

    August 13, 2019

    David Dolan, MBA
    Lead Analyst
    Centers for Medicare & Medicaid Services
    Attention: CAG-00452N
    P.O. Box 8013
    Baltimore, MD 21244-1850

    Submitted electronically via http://www.cms.gov

    Dear Administrator Verma,

    On behalf of over 34,000 orthopaedic surgeons and residents represented by the American Association of Orthopaedic Surgeons (AAOS), we appreciate the opportunity to provide comments on the Centers for

    More

    rossi, margot Date: 08/13/2019
    Comment:

    I support the points made in the following letter by the American Society of Acupuncturists:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    On behalf of the American Society of Acupuncturists and our 4500 members nationwide, we

    More

    Chen, Fengling Date: 08/13/2019
    Comment:
    Acupuncture treatment enables the recovery system of our own body for healing, and the treatment has no adverse effect as medicine does. It is unlike pain killers that only work on temporary relief and patients suffer from numerous adverse effects at the same time.
    Acupuncture treatment is also cost-effective for its long-lasting result from solving the root cause.
    Hersey, Rosemary Title: RN, L.Ac
    Organization: BodyMindSpirit Acupuncture and Wellness
    Date: 08/13/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    August 12, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    As an acupuncturist and registered nurse, I would like to applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a

    More

    Koonce, Jamie Date: 08/13/2019
    Comment:

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a representative of the Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, we seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    lee, chan young Organization: CalATMA
    Date: 08/13/2019
    Comment:
    1. The proposed document would allow certain non-acupuncturists to provide acupuncture services,
    2. It excluded California licensed acupuncturists who have not also been certified by the NCCAOM,
    3. It labeled licensed acupuncturists as "auxiliary personnel", and
    4. It initiated support for supervision of acupuncturists by physician assistants, nurse practitioners and/or clinical nurse specialists.
    WEE, IN JUN Date: 08/13/2019
    Comment:
    1. The proposed document would allow certain non-acupuncturists to provide acupuncture services,
    2. It excluded California licensed acupuncturists who have not also been certified by the NCCAOM,
    3. It labeled licensed acupuncturists as "auxiliary personnel", and
    4. It initiated support for supervision of acupuncturists by physician assistants, nurse practitioners and/or clinical nurse specialists.
    Allen, Collins Title: Asst. Professor
    Organization: N. E. School of Acupuncture @ MCPHS University
    Date: 08/13/2019
    Comment:
    I have practiced Chinese medicine: Acupuncture and Chinese herbal medicine, for the past twenty years and have been teaching Chinese medicine for the past fourteen years. My clinical experience includes private practice, the supervision of student interns in a variety of clinical settings, and providing acupuncture care at the Boston Medical Center in the departments of Family Medicine, Infectious Disease, and Internal Medicine.
    Acupuncture has proven to be an effective, safe alternative

    More

    Zevotek, Todd Title: L.AC.
    Date: 08/13/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan, I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As representatives of the Licensed Acupuncturist (L.Ac.) community and

    More

    Bertulfo, Mary Grace Date: 08/13/2019
    Comment:

    [PHI Redacted] I want to thank the CMS for your consideration of this important topic if adding acupuncture to Medicare so more Americans can receive it's benefits.

    However, in reading how the CMS proposes to investigate acupuncture here are a few recommendations:

    1. The section that includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent”. The qualifications for auxiliary providers exactly describe

      More

    fleming, jonathan Date: 08/13/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services 7500 Security Boulevard
    Baltimore, MD 21244
    August 13, 2019

    Dear Dr. Miller and Mr. Dolan:

    On behalf of the American Society of Acupuncturists and our 4500 members nationwide, we applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As representatives of the Licensed Acupuncturist (L.Ac.) community and

    More

    Seo, Jung Eun Title: California Licensed Acpuncturist
    Organization: CalATMA
    Date: 08/13/2019
    Comment:
    1. The proposed document would allow certain non-acupuncturists to provide acupuncture services,
    2. It excluded California licensed acupuncturists who have not also been certified by the NCCAOM,
    3. It labeled licensed acupuncturists as "auxiliary personnel", and
    4. It initiated support for supervision of acupuncturists by physician assistants, nurse practitioners and/or clinical nurse specialists.
    Shao, Xiaohong Title: Acupuncturist
    Organization: Pacific Holistic health center
    Date: 08/13/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    Egan, Michael Title: Licensed Acupuncturist
    Date: 08/13/2019
    Comment:

    To Whom it May Concern,

    Thank you for the opportunity to comment on the topic of acupuncture for low back pain.

    I am a licensed acupuncturist in the state of Minnesota.

    I work at the Penny George Institute for Health and Healing (Part of Allina Health). We are the largest integrative medicine clinic embedded within a large Health Care Organization in the USA.

    I collaborate with MD's, Spine Surgeons, Chiropractors and physical therapists.

    I

    More

    LEE, THOMAS Title: L.Ac.
    Organization: CalATMA
    Date: 08/13/2019
    Comment:
    The proposed document would allow certain non-acupuncturists to provide acupuncture services,
    2. It excluded California licensed acupuncturists who have not also been certified by the NCCAOM,
    3. It labeled licensed acupuncturists as "auxiliary personnel", and
    4. It initiated support for supervision of acupuncturists by physician assistants, nurse practitioners and/or clinical nurse specialists.
    Chung, Lucia Date: 08/13/2019
    Comment:

    Dear Dr. Miller and Mr. Dolan (U.S.Centers for Medicare and Medicaid Services):

    As a practicing licensed acupuncturist in the state of Hawaii, I thank you for CMS efforts to study the effects of acupuncture on low back pain on those covered by Medicare.

    I would like to point out, just for clarification purposes, that most if not all states in the U.S. require state and/or national certification exams for persons practicing acupuncture without supervision by PAs, NPs, or

    More

    Sammons, Travis Organization: Erchonia Corporation
    Date: 08/13/2019
    Comment:

    With reference to CMS National Coverage Analysis (NCA) Tracking Sheet for Acupuncture for Chronic Low Back Pain (CAG-00452N).

    We would like to propose a beneficial change in which the coverage and inclusion criteria would encompass preceding noninvasive devices, that have obtained an FDA 510k related to the treatment of chronic low back.

    Particularly in which, Erchonia Corp received an FDA 510k for the treatment of Chronic low back pain (K180197) in Feb 2018. The FDA

    More

    Kaplan, Ross Title: ND L.OM Acupuncture Physician
    Date: 08/13/2019
    Comment:

    Thanks to CMS for considering and studying Acupuncture as a potential covered benefit for low back pain. I am excited about the potential for public benefit this inquiry may produce, especially in light of the opioid crisis and the need for access to non pharmacologic choices in pain management.

    I am an Acupuncture Physician/Practitioner of Oriental Medicine, licensed in Pennsylvania and Florida for 27 years. Upon reading the parameters of the study it was glaringly evident to

    More

    PHAN, CHARLES Title: MSOM, FCIM Graduated Student
    Organization: Florida State Oriental Medical Association (FSOMA)
    Date: 08/13/2019
    Comment:
    We have 3000+ hours of training with 600 hours supervised in the clinic. We are considered primary care healthcare providers in the state of Florida. Our licenses allow us to see patients independently, diagnose and provide procedures (acupuncture) treatments. This would highly be advantageous for patients in terms of pain management in general as well as general coverage to help medicare patients. Have the benefits with primary medicare, this would open more benefits for other health

    More

    Dougherty, Nicholas Title: DAOM, L.Ac
    Organization: MN Acupuncture Association (MAA)
    Date: 08/13/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    August 14, 2019

    Re: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan,

    The Minnesota Acupuncture Association (MAA), on behalf of our members, the patients they care for and colleagues across the state of MN, applaud the effort of the CMS to further study the effects of

    More

    Valdes, Vladimir Title: AP
    Date: 08/13/2019
    Comment:
    I had been using Acupuncture as first choice of treatment for any type of pain for the last 30 years with a very high percent of pain relief more than 90 % of acupuncture treatments was very effective,reducing the use of drugs for pain per patients.
    Alberti, Jennifer Title: Acupuncturist
    Organization: Fenway Health
    Date: 08/13/2019
    Comment:

    As a Licensed Acupuncturist in Massachusetts, I applaud the Centers for Medicare and Medicaid Services for moving forward in studying the effects of acupuncture on low back pain. Acupuncture has proven time and again to be an effective tool for acute and chronic pain, and I look forward to seeing the results of this study.

    I want to show my support for the research being done, but also would like to add to this my support for the inclusion of Licensed Acupuncturists, rather than

    More

    Huang, Guofu Date: 08/13/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    Picker, Caroline Title: Community Acupuncturist
    Organization: People's Organization of Community Acupuncture (POCA)
    Date: 08/13/2019
    Comment:
    From firsthand experience giving 5,000 acupuncture treatments a year in a busy community acupuncture clinic, I know how effective acupuncture is for chronic pain relief. I am in full support of making this safe, simple, low cost and effective as widely available and accessible to as many people as possible and hope that this will move forward.
    Zhang, Ning Title: Ultrasound technologist
    Organization: Alhambra medical University
    Date: 08/13/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    gu, hua Title: Ph.D.,L.Ac.
    Date: 08/13/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    WALLS, DICKIE Title: DOCTOR OF ACUPUNCTURE AND ORIENTAL MEDICINE
    Organization: ATLANTIC INSTITUTE OF ORIENTAL MEDICINE
    Date: 08/13/2019
    Comment:

    August 12, 2019

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services 7500 Security Boulevard
    Baltimore, MD 21244

    Dear Dr. Miller and Mr. Dolan,

    We in the acupuncture community are grateful and supportive of your study to determine the effects of acupuncture in the treatment of low back pain. I hope that your are selecting qualified licensed professionals to provide the treatments in your studies.

    I am a clinical instructor

    More

    Jernejcic, Randy Organization: Northeast Ohio Hospital Opioid Consortium
    Date: 08/13/2019
    Comment:

    David Dolan
    Susan Miller, MD
    Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    Dear Mr. Dolan and Dr. Miller:

    On behalf of the Northeast Ohio Opioid Consortium, I would like to express support for the Centers for Medicare and Medicaid Services’ consideration of acupuncture as a Medicare-covered treatment option for patients with chronic low back pain.

    The Northeast Ohio Hospital Opioid Consortium is a hospital

    More

    Pardo, Gisela Organization: Integrative Path Therapies, LLC
    Date: 08/13/2019
    Comment:
    I have enormous success when treating low back pain with acupuncture and massage. This should be included in all basic insurance coverage.
    Carrillo, Christina Organization: True Care, Inc
    Date: 08/13/2019
    Comment:
    Being an Acupuncturist in the state of Florida has allowed patients to have access to me without the need of an outside refferal. An issue such as chronic "Low Back pain" is not one that requires a middle man. A patient should have the right to seek out pain relief without having to worry about how they will pay for it. In Florida we are primary care providers. That means that I have to complete over 600hrs of clinical studies before graduating, pass 4 state boards - we deserve the respect

    More

    Lin, Qianqian Date: 08/13/2019
    Comment:

    I want to thank CMS for consideration of the Acupuncture for Chronic Lower Back Pain Study. This represents a big step towards the incorporation of acupuncture into national health care.

    Please change the section that reads: “Auxiliary personnel furnishing acupuncture must be under the direct supervision of a physician, physician assistant, or nurse practitioner/clinical nurse specialist”.

    The section that includes “auxiliary providers” should be changed to: “Licensed

    More

    Searcy, David Date: 08/13/2019
    Comment:
    Finally you are taking a great step in helping patients relieve back pain, should also include Knee and neck pain, without having to take unnecessary medication. I do not understand why you do not include Acupuncturist (only or National Board Certified Acupuncturist) to conduct the trials. Acupuncturist only study this art of Medical Practice and only concentrate on this practice to ensure the patient is receiving the best possible treatment for his/her condition. Acupuncturist must have at

    More

    Milligan, Cynthia Title: Acupuncturist - MAOM LAc.
    Organization: To the Point Healthcare
    Date: 08/13/2019
    Comment:

    AUGUST 12, 2019

    REMINDER: CALL TO ACTION!! DEADLINE IS AUGUST 15
    WHEN YOU GET TO THE COMMENT PAGE - You have to click on CMS PHI Posting Policy and spend some time reading it, then click on the box next to "I have read and understand the CMS policy regarding redaction of PHI". Then you can put in your information and leave your comment
    Include some information from here
    Ask that the section that includes “auxiliary providers” be changed to more clearly nam

    More

    Zhang, Lei Title: LAc
    Date: 08/13/2019
    Comment:

    Dear Sir/Madam,

    I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As many Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse

    More

    Conrrique, Roberto Date: 08/13/2019
    Comment:

    * As an acupuncturist who treats thousands of patients a year, many of whom are suffering from back pain, I really hope the studies include acupuncture treatment that is 'distal' to the location of the pain. I say this because simply inserting the needles into the location of the pain is significantly less effective than inserting them remotely. This is probably why much of the research findings are a bit lackluster. Unfortunately acupuncture students are not taught these more effective

    More

    Eisenman, Donald Title: Doctor
    Organization: Holistic primary care
    Date: 08/12/2019
    Comment:
    I have treated many patients for acute / chronic pain
    With much success using Acupuncture and Neuromuscular therapy . I have helped many patients to return to a happy and healthy lifestyle while saving thousands of dollars in medical cost .
    Surin, Yves Title: AP
    Organization: The health Enlightened Acupuncture and NAtural Medicine
    Date: 08/12/2019
    Comment:
    I have had many patients with chronic back pain that got good relief of their pain with only acupuncture treatment. I think it's a good idea to conduct that study which I am sure will enlighten many about acupuncture treatment with no drugs.
    gottesman, simm Title: Licensed Acupuncturist
    Organization: sole practitioner acting on my own
    Date: 08/12/2019
    Comment:

    The Notion that CMS, is going to require that there ONLY be supervision, by an MD for this study, regarding Acupuncture's effect on Low back pain, is just Not right.

    The section that includes “auxiliary providers” should be changed to more clearly name “Licensed Acupuncturists" or maybe the "equivalent” of others that at least have the same amount of training that “Licensed Acupuncturists" are required to have. The qualifications for auxiliary providers, does Not exactly

    More

    Huang, Elaine Title: Acupuncture Physician, Doctor of Oriental Medicine
    Organization: FSOMA
    Date: 08/12/2019
    Comment:

    Thank you CMS for taking into considering acupuncture treatment in clinical studies on low back pain. As a licensed acupuncture physician in the state of Florida, I can attest to acupuncture's effectiveness in treating acute and chronic low back pain. The majority of my patients seek relief for back pain and 95% of those patients experience varying degrees of relief just after 1 treatment. Acupuncture is a cost-effective, non-pharmaceutical, and non-invasive pain management therapy.

    More

    QIN, Bolin Title: Ph.D, L.Ac, C.MD
    Date: 08/12/2019
    Comment:
    It is very important to choose a qualified acupuncturist to join the clinical research team in the evaluation of the clinical effects of acupuncture for chronic low back pain in senior patients. It's well known, the effect of acupuncture treatment is closely related to the medical level and clinical experience of acupuncturists, and the background of education and training. A true acupuncturist usually receives 3000 hours of regular education of acupuncture, but now many practitioners of

    More

    Cloud, Sy Title: Acupuncturist
    Organization: Natural Health Center, LLC
    Date: 08/12/2019
    Comment:
    Thank you for conducting this study regarding the efficacy of acupuncture in treating back pain. As a practicing acupuncturist in Alaska I have had tremendous success in helping people recover from injuries to their low backs and in reducing their pain level. With the help of my patients' prescribing doctors I help facilitate reducing dependency on pain medication.
    One comment I have however is to request "auxiliary providers" be changed to "Licensed Acupuncturists" in the study. I

    More

    Cetan, Mary Title: Doctor of Oriental Medicine-Acupuncture Physician
    Organization: Nature's Wisdom Healing Center - Mary Cetan
    Date: 08/12/2019
    Comment:
    I am Florida board certified acupuncture physician and have been since 1999. I have been serving Sarasota, Florida in clinical practice as a primary healthcare provider since December 1999 as an Acupuncture Physician (after I graduated with my Master's Degree in Oriental Medicine and passed my Florida acupuncture medical exam). Did you know that in Florida we have 2700+ hours of training with 600 hours supervised in the clinic before we take our state board? After we are licensed, we need

    More

    Monteiro, Cris Title: Dr. of Acupuncture and Oriental Medicine
    Organization: POCA Coop
    Date: 08/12/2019
    Comment:

    It's great that CMS is proposing acupuncture services for cLBP and as a clinician in a busy clinic that delivers ~20K txs annually I know that many people get relief from chronic LBP when they can access acupuncture, both because of affordability (or coverage) and when they need it.

    However, an important distinction needs to be clarified with regard to acupuncture licensing and certification. Most states require acupuncturists to have passed a national certification exam. A few

    More

    zhong, qinghui Organization: Asian Health Link
    Date: 08/12/2019
    Comment:

    Thanks CMS for considering acupuncture to be covered by national health care. Acupuncture services are already covered by many commercial insurance plans. This step could bring great benefits to the patients as well as the care plans.

    As for the trial, I strongly recommend that licensed acupuncture experts must involve in all the clinical trial stages of design, course of treatment and outcome evaluation. In the field of acupuncture, only licensed acupuncturists has the best

    More

    Back, Hilary Organization: Back to Balance
    Date: 08/12/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    August 12, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    I am excite to hear that the CMS is going to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a Licensed Acupuncturist (L.Ac.),

    More

    HA, JUNGHO Date: 08/12/2019
    Comment:
    Indigestion lower back pain is very common in Oriental Medicine:based on Holistic Approach. Acupuncture and Herbs are well designed to treat Indigestion lower back pain due to Stress. Back pain often occurs because some people who are experiencing stress tense their muscles unconsciously. Stress changes the body, not just the mind. Intense stress or anxiety can trigger both back pain and stomach discomfort, including bloating. Stomach pain and bloating are more common in people who have stress

    More

    Speyer, Simone Title: Dr, A.P.DPT
    Organization: Naturalhealthadvantage,Inc
    Date: 08/12/2019
    Comment:
    As a physical therapist and a licensed acupuncturist
    With 34 yrs experience in health care as a provider
    Have seen many patients who did not respond to Physical Therapy or epideurals or medications. Some patient could not take medications and found that acupuncture was then only thing that worked.
    Acupuncture works to reduce pain and it is drugless
    Perry, Elizabeth Title: Founder
    Organization: Perry Family Health Incorporated
    Date: 08/12/2019
    Comment:
    My observation over the past five years regarding chronic low back pain patients, they have substantially benefitted from receiving acupuncture. The improvement of lessened back pain has carried from 30-100 percent improvement. Most patients seem to benefit most from receiving 14 treatments within three months.
    Byers, Susana Title: Acupuncturist
    Organization: Susana Byers, Lic. Ac
    Date: 08/12/2019
    Comment:

    It is wonderful that you are planning to study the effects of acupuncture for chronic low back pain in populations covered by Medicare. This is a huge step towards the incorporation of acupuncture into national health care.

    As a licensed acupuncturist (L.Ac.), in Massachusetts and California, I ask that you change the section that includes “auxiliary providers.” To more clearly state something to the effect of:

  • Licensed Acupuncturists or state equivalents who carry an

    More

  • Doerr, Sarah Date: 08/12/2019
    Comment:
    Please make sure that you are utilizing licensed acupuncturists for this study in order to get accurate results please!
    Caldwell LAc, Esly Title: licensed acupuncturist
    Organization: Caldwell Family Wellness
    Date: 08/12/2019
    Comment:

    To Whom It May Concern:

    First of all, thank you very much for considering allowing Medicare coverage for acupuncture for low back pain. It is one of the most common issues we treat, and one of the most common issues that senior citizens call us asking if Medicare will cover.

    There is considerable research showing the benefits of acupuncture for chronic low back pain and many other issues. It is something that most insurance plans- including Medicaid here in Ohio and some

    More

    Park, Hye Date: 08/12/2019
    Comment:
    Please approve the acupuncture treatment because this treatment helps chronic pain without medicine.
    Putnam, Bobbie Jo Title: Licensed Acupuncturist
    Organization: Association for Professional Acupuncture in Pennsylvania
    Date: 08/12/2019
    Comment:

    Thank you, CMS, for taking the time to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As a Licensed Acupuncturist (L.Ac.) and acupuncture educator, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse practitioners/clinical nurse specialists (as identified in 1861(aa)(5)), and auxiliary personnel may furnish acupuncture if

    More

    Park, Saeong Bin Date: 08/12/2019
    Comment:
    I think the acupuncture treatments helps to release the back pain, shoulder pain, headache like chronic pain.
    Please approve this treatments.
    Thank you.
    Wang, Guansu Title: Acupuncturist licensed in Florida
    Organization: Sunshine Acupuncture Center
    Date: 08/12/2019
    Comment:

    Dear CMS,
    As a licensed Acupuncturist in Fl for decades and former MD in China, I thank CMS for their consideration of this topic.

    Acupuncture as part of the Chinese medicine has been practiced as the holistic medicine system over the world.

    Many clients have been helped regarding lower back pain in particular and overall better quality of life in my decades of practice..

    I applaud this initiative and it is high time.

    As for the protocol of the study,

    More

    Murphy, Erin Title: Dr
    Organization: Local Healing House
    Date: 08/12/2019
    Comment:

    Thank you for your consideration in using Acupuncture for chronic low back pain.

    I am currently researching injury induced apoptosis from traumatic injury along the spine. I hope to publish my results after I present my findings in October. What I have found is biochemical responses to Acupuncture that can facilitate the healing process in the spinal cord through a meta-analysis. That being stated, I have clinically helped patients and worked along with other medical provider

    More

    Lee, Christopher Title: Licensed Acupuncturist
    Organization: Kaiser Permanente
    Date: 08/12/2019
    Comment:

    First, thank you CMS for considering acupuncture as a treatment option for chronic low back pain. Acupuncture has been frequently studied and shown to be an effective treatment option for low back pain. With the current opioid epidemic, it is crucial for patients in the USA to have access to effective non-opioid pain relief, which acupuncture can provide.

    I believe that the section that includes "auxiliary providers" should be changed to a clearer and more accurate description. In

    More

    Teeter, Martha Title: Exectutive Director
    Organization: Florida State Oriental Medical Association
    Date: 08/12/2019
    Comment:
    Thank you for exploring this. Please change the section that includes “auxiliary providers” be changed to more clearly name “Licensed Acupuncturists or state equivalent”. In Florida we have over 2700 hours of classroom training and 600 hours of supervised clinical training. We are the experts in acupuncture and should be specified.
    We are considered primary healthcare providers under Florida Law.
    It is important that an MD supervise this study, supervision by other licensure

    More

    Leung, Thomas Date: 08/12/2019
    Comment:

    As being a registered physical therapist and licensed acupuncturist for more than 35 years, I have being treating countless number of low back pain patients. It is very obvious that acupuncture is a very powerful method to manage the pain and help patients to restore a quality life.

    I highly welcome the CMS to start this study to look into the effectiveness of acupuncture in chronic low back pain. It can surely will contribute more evidence to the effectiveness of

    More

    McNulty, Maureen Title: Dipl OM, L.Ac.
    Organization: Extraordinary Acupuncture
    Date: 08/12/2019
    Comment:
    Thank you for your consideration in covering acupuncture services for chronic low back pain through Medicare. I can assure you, from my own experience, that individuals often "cannot believe it [acupuncture] worked" in resolving their chronic pain or alleviating it in order for them to be able to continue to work or perform daily tasks. Acupuncture, often used with other modalities such as manual therapy, is effective.
    I am a licensed acupuncturist, a nationally certified herbalist and

    More

    Abadie, J Paul Title: Mr.
    Organization: Abadie Integrative Therapy
    Date: 08/12/2019
    Comment:

    Dear CMS:

    The purpose of this submittal is to, first, thank you for consideration of Acupuncture Coverage for treatment of Low Back Pain; and, second to strongly urge you to change wording in the proposal that reads "auxiliary providers" to more clearly name "Licensed Acupuncurist; or, state equivalent" as the profession of practitioners who are fully trained and qualified to administer this care with the most favorable outcomes read; safety & effectiveness.

    The State of

    More

    fanucchi, joanne Title: L.Ac.
    Organization: acupuncture and herbal medicine clinic
    Date: 08/12/2019
    Comment:

    Acupuncture is the health care method of choice by most people. People over 65, just when they need it have no insurance coverage for it.

    It's pretty disgusting.

    Acupuncture will PREVENT many illnesses. it will HELP with screw ups by western MD's.

    I've been in practice 16 years and am appalled every time I have to tell an elder that medicare doesn't cover acupuncture.

    Do the right thing for a change.

    Marx, Sandra Date: 08/12/2019
    Comment:
    I am not an acupuncture professional. I am a consumer. [PHI Redacted] As a senior citizen, continuing to engage in movement is critical to well being and over all health. [PHI Redacted] I fail to understand why it is not covered by Medicare. I consider that unjust.
    I appreciate the invitation for public comment. Again, I am not an acupuncturist, I am just a consumer. But isn't that who you, as a public agency, are here to serve? There is a gaping hole in

    More

    Yu, Jia Title: Acupuncturist
    Organization: Yu Dayi Chinese Medicine
    Date: 08/12/2019
    Comment:

    Ref: National Coverage Analysis (NCA) for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller, Mr Dolan & CMS Committee members,

    First, we are grateful to the CMS for conducting a clinic trial investigating acupuncture’s effectiveness to treat chronic low back pain (cLBP) in geriatric patients. We understand the need that federal health care legislators seek further evidence for the effectiveness of acupuncture in order to justify federal coverage with

    More

    LAc, Danit Polunsky Organization: Dragon's Lair Acupuncture
    Date: 08/12/2019
    Comment:

    I think including acupuncture for Low Back Pain in Medicare/Medicaid is a brilliant idea. I think the medical profession will find other ailments treated and alleviated in treating low back pain.

    I feel that this needs to be limited to Licensed Acupuncturists. Firstly, this is a deep well of information LAc's have invested in to earn their license. This should be protected. The use of acupuncture needles is only representative to the practitioner's education. Should any other

    More

    Wu, Moonching Organization: Moonching Wu Acupuncture PLLC
    Date: 08/12/2019
    Comment:
    Thank CMS for their consideration of this topic.
    I wans to ask that the section that includes “auxiliary providers” be changed to more clearly named “Licensed Acupuncturists or state equivalent.” The qualifications for auxiliary providers accurately describe this licensure group.
    Make commentary directly about the laws in my state to highlight my required training, supervision (or lack thereof), and certification.
    I ask that the supervision required during the study portion be

    More

    Rosen, Raquel Title: MD
    Organization: Bassett Healthcare/ Columbia Medical School
    Date: 08/12/2019
    Comment:
    It is a breath of fresh air to see the move towards a more holistic approach to chronic issues, ie: back pain.
    Being a nephrologist and having dialysis patients experience pain, with treatment limited to NSAID (which makes then experience GI bleeding), narcotics (which cause altered mental status, seizures and fall with significant injuries and trauma), and psychoactive drugs (which affect their quality of life) this is a great modality with no complications when done properly.
    I am

    More

    Dong, Daisy Title: L. Ac. CMD
    Organization: University of Colorado Health
    Date: 08/12/2019
    Comment:
    Our integrative medicine center has treated lower back pain daily for the last 18 years. Many patients no longer depend on opiate-based Rx but taking NSAIDs, prn.
    Chronic lower back pain is consist of 40% acupuncture schedules on a daily schedule.
    Many patients with Medicare or Medicaid have to pay out of pockets for acupuncture. As a result, those people could not finish the treatment course 6-10/course as we recommended. According to research studies, acupuncture treatment shows

    More

    Huynh, Long Title: L.Ac.
    Organization: Acupuncture Healing Center
    Date: 08/12/2019
    Comment:
    I have been & still am treating LBP to at least 50% of VCP (US Veteran) patients every day & they all response possible after many other treatment modalities couldn't help.
    I have patients unable to walk at all with LBP, & after many acupuncture treatments, they are able to walk normally without taking any medicines for the rest of their lives.
    I can have all of these vet patients to be our evidence of how effective acupuncture can help them live without pain, not just LBP, but also

    More

    Arcand, John Title: DiplAc, MS, NYS licensed Acupuncturist
    Organization: Arcand Acupuncture
    Date: 08/12/2019
    Comment:
    My clinical experience is that Acupuncture "does" treat low back pain extremely effectively. From both a Western science standard and Eastern. It reduces the need for expensive surgeries, and also helps people take better care of themselves. Often times just treating the muscle group surrounding a diagnosed medical issue. Reduces pain and loosens the muscle allowing the patient to heal the affected area.
    Wrobleski, Melissa Title: Office Manager
    Organization: Peachtree City Acupuncture
    Date: 08/12/2019
    Comment:
    Please include Licensed Acupuncturists as an auxiliary provider. I strongly believe that acupuncture should be included as an effective and safe modality for low back pain in older Americans. Thank you for your consideration!
    Frank, Harris Title: LAc, DTCM
    Organization: Peachtree City Acupuncture
    Date: 08/12/2019
    Comment:
    Thank you for working to include acupuncture for low back pain as a covered service in Medicare and Medicaid. I am a community-care provider for the VA providing relief for low back pain in the veteran population, caring for 100s of veterans a month. This population responds very well to acupuncture for low back pain, as well as many other pain conditions, reducing their need for prescription drugs, and more expensive and invasive procedures.
    As the primary providers offering acupuncture

    More

    Frank, Mara Title: DTCM, LAC
    Organization: Peachtree City Acupuncture
    Date: 08/12/2019
    Comment:
    Thank you for your consideration of this topic.
    Please include Licensed Acupuncturists explicitly as an auxiliary provider. As a GA licensed acupuncturist a have a 4 year masters degree, a 3 year doctorate degree, National Certification, and GA licensure. I believe as the group of providers doing the most acupuncture for low back pain patients, we need to be included.
    Thank you again for considering acupuncture as an effective and safe modality for low back pain in older Americans.
    Lewis, Amy Title: President
    Organization: Acupuncture Society of Washington, DC
    Date: 08/12/2019
    Comment:

    Mr. David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare and Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    August 7, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan,

    The Acupuncture Society of Washington, DC (ASCD) is an organization representing licensed acupuncturists in the District of Columbia and is a member state of the national organization, American

    More

    BLACK, JENNIFER Organization: J BLACK ACUPUNCTURE, INC
    Date: 08/12/2019
    Comment:

    For the section that includes “auxiliary providers” I would like to request that you please change the verbage to the more clearly named “Licensed Acupuncturists or state equivalent.”

    Please have the study portion be done only by an MD.

    Thank you.

    Black, Jennifer Title: LAc
    Organization: J BLACK ACUPUNCTURE, INC
    Date: 08/12/2019
    Comment:
    Thank you for your consideration of this topic.
    GRAY, Leslie Title: Licensed Acupuncturist
    Organization: Community Acupuncture West
    Date: 08/12/2019
    Comment:
    Acupuncture by people who have done at least 3500 hours of Traditional Chinese Medicine education in my opinion are the only ones who have full understanding of treating with acupuncture. This medicine is thousands of years old and it still works. Those of giant egos just looking for money destroy the goodness in the world
    Carrigan, Michael Title: Licensed Acupuncturist
    Date: 08/12/2019
    Comment:

    Thank you CMS for your consideration in this proposal. In the section that includes" auxiliary providers" please change "auxiliary providers" to" Licensed Acupuncturist." I am a licensed acupuncturist in the state of North Carolina with a strict Acupuncture Law requiring three years of formal acupuncture study from an accredited educational institution and passing a series of National Exams given by the National Certification Commission for Acupuncture and Oriental Medicine before the

    More

    Baptie, Bruce Title: Licensed Acupuncturist
    Organization: Advanced Health
    Date: 08/12/2019
    Comment:

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    July 24, 2019

    RE: Proposed Decision Memo for Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Dr. Miller and Mr. Dolan:

    On behalf of the American Society of Acupuncturists and our 4500 members nationwide, we applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in

    More

    Blankenship, Cheryl Title: LAc.
    Organization: Island Acupuncture and massage
    Date: 08/12/2019
    Comment:
    I am very glad to see this study happening. I do however have issue that Licensed Acupuncturists are not included for providing services. Please include Licensed Acupuncturists in the providers providing acupuncture. If these services are not provided by the field professionals, how on earth would you be able to make a determination of efficacy? Thank you for your time.
    Wilkes, Sandra Title: L.Ac.
    Organization: Blue Valley Acupuncture
    Date: 08/12/2019
    Comment:
    The Acupuncture for Chronic Low Back Pain Trial practitioner group should include Licensed Acupuncturists. Licensed Acupuncturists are the most fully trained in Acupuncture of any practitioner and the acupuncturists of choice for many patients.
    Thank you.
    Browning, Ginna Date: 08/12/2019
    Comment:
    Thank you for considering acupuncture as an effective pain management tool in health care. For the Chronic Low Back pain study, I recommend utilizing Licensed Acupuncturists, or the state equivalent of acupuncture licensure, which requires 2800 hours of training in my state, North Carolina. The criteria for "auxiliary providers" needs to meet this standard of care for the Low back pain study, and should specify Licensed Acupuncturists as the preferred provider in the study; as this will ensure

    More

    Shibao, Shirley Date: 08/12/2019
    Comment:
    It is clear to me that acupuncture treatment, by a LICENSED acupuncturist is the best option, for treating acute & chronic back pain. [PHI Redacted] I humbly but firmly request your help to please provide patients with the best care & options to help reduce pain & normalize functional abilities. Acupuncture treatment, by licensed & highly trained practitioners, really make a difference for patients with chronic low back pain & needs.
    Marulanda, Lucy Title: DAOM L.Ac
    Organization: Codac Behavioral Health
    Date: 08/12/2019
    Comment:

    To whom it may concern at CMS,

    The state association for acupuncturists in Arizona has informed its members about the following idea:

    “The Centers for Medicare & Medicaid Services (CMS) proposes to cover acupuncture under section 1862(a)(1)(E) of the Social Security Act (the Act), with the support of the Agency for Healthcare Research and Quality under section 1142 of the Act.  We propose that coverage would be available for Medicare

    More

    Yuan, Roy Date: 08/11/2019
    Comment:
    This study can only be conducted by established acupuncturist, for the best benefits of patients. If any inconsistent results got by non established acupuncturist will only mislead the direction of study.
    Van Fleet, Nelson Date: 08/11/2019
    Comment:

    [PHI Redacted] I applaud efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. As my colleagues in the Licensed Acupuncturist (L.Ac.) community and other relevant stakeholders affected by the decisions made based on the outcomes of the planned studies, I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician

    More

    Goldfarb, Steven Title: Acupuncturist
    Date: 08/11/2019
    Comment:
    Thank you for considering the study regarding acupuncture as a treatment for chronic low back pain. I am requesting that the section that includes “auxiliary providers “be changed to more clearly name “licensed acupuncturist “or state equivalent. In the state of New Jersey where I am a licensed acupuncturist, no supervision or referral is necessary by a medical doctor or another healthcare provider for the patient to be treated by an acupuncturist. The required training to become a

    More

    tang, Daiyi Organization: Florida Acupuncture Association
    Date: 08/11/2019
    Comment:

    Thank CMS for consideration of the Acupuncture for Chronic Lower Back Pain Study. This represents a big step towards the incorporation of acupuncture into national health care.

    Please change the section that reads: “Auxiliary personnel furnishing acupuncture must be under the direct supervision of a physician, physician assistant, or nurse practitioner/clinical nurse specialist”.

    The section that includes “auxiliary providers” should be changed to: “Licensed Acupuncturists

    More

    Huang, Jack Organization: Solution Heal LLC
    Date: 08/11/2019
    Comment:
    It would be wonderful if acupuncture becomes a covered service under Medicare. However, licensed acupuncturists should get involved during the process of the study as service providers and placed under Benefits Category. I have seen insurance policies that cover acupuncture service but the service can only be rendered by MD and DO because acupuncturist is often not considered as a physician in this country. It means that people either will have a hard time finding acupuncture service providers

    More

    Chu, Kenny Date: 08/11/2019
    Comment:
    I have two comment :
    1. License Acupuncturists should be the main acupuncture provider work together with MDs.
    2. California licensed acupuncturists without NCCOAM certification should be included. Licensed acupuncturists trained overseas should be included.
    Lerner, James Title: Licensed Acupuncturist
    Date: 08/11/2019
    Comment:
    I support CMS studying acupuncture for chronic low back pain, as well as for other conditions. I have been an acupuncturist for 36 years, and have seen its benefits for many medicare age patients. It is currently a covered benefit for veterans, and only makes sense to broaden its use. Acupuncture has the potential to improve quality of life and reduce medication usage for back pain patients.
    Urick, Yuemei Bai Organization: Natural Healings
    Date: 08/11/2019
    Comment:
    Acupuncture is an excellent pain management. It has been used by LAcs, MDs and other health practitioners to relieve verious chronic pains of all age group of people. It is safe with proper training, and no risk of chemical interactions. I believe it will benefit greatly to the most needed group of patients, if it becomes part of their health insurance benefit.
    Lusby, annie Date: 08/11/2019
    Comment:
    The acupuncture treatment is very effective for chronic and acute back pain without any side effects. It is very benefits for all of the Americans.
    YANG, YIMU Date: 08/11/2019
    Comment:
    Acupuncture effects body pain, specially for low back pain. The articles (about 798 papers) published in NCBI can support it.
    Fox, Michael Title: Founder and Licensed Acupuncturist
    Organization: Silverlake Acupuncture, Inc.
    Date: 08/11/2019
    Comment:

    August 11, 2019

    RE: Acupuncture for Chronic Low Back Pain (CAG-00452N)

    Dear Mr. Dolan and Dr. Miller:

    I am a licensed acupuncturist in California and nationally certified by the NCCAOM diplomate in Oriental Medicine. I practice in Los Angeles. Thank you for requesting comments regarding efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered by Medicare. While many licensed California acupuncturists are

    More

    moiduddin, samina Date: 08/11/2019
    Comment:

    Thank you for your consideration towards this topic. I request that section, auxiliary providers, be changed to more clearly name licensed acupuncturists or state equivalent. I ask the supervision of this study be only performed by an MD.

    Thanks!
    Fox, Michael Title: Board of Trustees & Communications Committee Chair
    Organization: CalATMA
    Date: 08/11/2019
    Comment:

    August 4, 2019

    David Dolan
    Susan Miller, MD
    U.S. Centers for Medicare & Medicaid Services
    7500 Security Boulevard
    Baltimore, MD 21244

    Dear Dr. Miller and Mr. Dolan:

    On behalf of the California Acupuncture and Traditional Medicine Association (CalATMA), our members, and the 12,185 licensed acupuncturists in the state of California, we commend the efforts by CMS to study the effects of acupuncture for chronic low back pain (cLBP) in populations covered

    More

    Tian, Haihe Title: AP
    Organization: Chinese Acupuncture and Herbs Center
    Date: 08/11/2019
    Comment:

    Acupuncture is one of the best options for Chronic lower back pain, we have been using acupuncture treated thousands and thousands these kind patients and achieved very positive results.

    12 weeks trail is good designation.

    The qualification of the providers are important, Acupuncture license in that state should be the basic requirement which can ensure the safety and the treatment effects.

    Also please put the acupuncturists into the CMS

    More

    Mangum, Jody Title: Licensed Acupuncturist
    Organization: The Wellness Center
    Date: 08/11/2019
    Comment:
    While studying Traditional Chinese Medicine at Samra University of Oriental Medicine in Los Angeles, everyone was very excited about Medicare considering the coverage of acupuncture care. The bill was HR 747 and the year was 1997. It is my hope that the services will be covered and at an equitable rate of compensation for the time it takes to care for my patients. Thank you.
    Osborne, Molly Title: MAOM, L.Ac
    Date: 08/10/2019
    Comment:
    First, this is great that you are considering acupuncture for low back pain for medicare recipients because it works! However, as a licensed acupuncturist and herbalist I do not see on this proposal that an acupuncturist will be able to provide these services. Acupuncturists are the best qualified to provide acupuncture and my degree is a 4 year Masters degree in Acupuncture and Oriental Medicine. Please reconsider adding acupuncturists as the primary provider in your proposal for

    More

    Komada, mary jo Title: LIcensed Acupuncturist
    Organization: NCCAOM . National Certification Commission for Acupuncture and O
    Date: 08/10/2019
    Comment:

    To Whom It May Concern,
    Many thanks to Medicare and Medicaid ( CMS) for considering to study the research and possibly include acupuncture for low back pain for Medicare payment. Rather than have auxiliary providers performing acupuncture, however, I believe that only State and nationally licensed acupuncturists and Medical Doctors with acupuncture training should administer acupuncture services in the future. In most states, acupuncture study requires a four year course of study,

    More

    Bindeman, John Date: 08/10/2019
    Comment:

    I want to thank CMS for consideration of the Acupuncture for Chronic Lower Back Pain Study. This represents a big step towards the incorporation of acupuncture into national health care.

    Please change the section that reads: “Auxiliary personnel furnishing acupuncture must be under the direct supervision of a physician, physician assistant, or nurse practitioner/clinical nurse specialist”.

    The section that includes “auxiliary providers” should be changed to: “Licensed

    More

    He, Hongjian Title: AP,DOM
    Organization: Florida Acupuncture Association
    Date: 08/10/2019
    Comment:

    I want to thank CMS for consideration of the Acupuncture for Chronic Lower Back Pain Study. This represents a big step towards the incorporation of acupuncture into national health care.

    Please change the section that reads: “Auxiliary personnel furnishing acupuncture must be under the direct supervision of a physician, physician assistant, or nurse practitioner/clinical nurse specialist”.

    The section that includes “auxiliary providers” should be changed to: “Licensed

    More

    Federowicz, Ann Title: LAc.
    Date: 08/10/2019
    Comment:

    As a Licensed Acupuncturist (L.Ac.), I seek clarification on certain aspects of the decision memo recently issued. The text of greatest relevance is highlighted below:

    Physician assistants, nurse practitioners/clinical nurse specialists (as identified in 1861(aa)(5)), and auxiliary personnel may furnish acupuncture if they meet all applicable state requirements and have:
    "A masters or doctoral level degree in acupuncture or Oriental Medicine from a school accredited by the

    More

    Lee, Thomas Title: L.Ac., Ph.D.
    Organization: United Acupuncture Association
    Date: 08/10/2019
    Comment:
    I have been a licensed acupuncturist in California since 1983 and have had a clinical practice for over 30 years. In my practice, I find numerous patients benefited from acupuncture