Comment letters & briefings

ASPN engages directly with CMS, Medicare Administrative Contractors, and commercial payers to protect patient access to interventional pain therapies. Each letter and briefing below is available in full as a PDF.

Position statement

Competency-Based Training and Certification for Minimally Invasive Spine Interventions and Surgery

ASPN's position is that patient safety and treatment efficacy should be determined by demonstrated competence, not by the specialty a physician trained in. The statement proposes a national, multispecialty Minimally Invasive Spine credential with procedure-specific requirements that scale with risk, identical terminal standards for every physician, objective assessment, and ongoing maintenance. It is endorsed by the Society of Women Innovators in Pain Management (WIPM) and the Sierra Spine Society.

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Document cover: ASPN requests reconsideration of Humana and Cohere's psychological evaluation requirement for basivertebral nerve ablation

Reconsideration request

ASPN requests reconsideration of Humana and Cohere's psychological evaluation requirement for basivertebral nerve ablation

The American Society of Pain and Neuroscience (ASPN) has submitted a formal request that Humana and Cohere reconsider their interpretation of Local Coverage Determination language for basivertebral nerve ablation (BVNA) in Medicare Advantage patients, under which every candidate must obtain a separate psychological evaluation from an independent mental health provider prior to authorization. Writing on behalf of more than 4,000 physicians, ASPN demonstrates that the pivotal BVNA trials used a validated screening threshold rather than a psychiatric clearance requirement, that pooled analyses show depression score is at most a weak predictor of outcome, and that vertebrogenic pain is defined by objective MRI criteria. ASPN requests that the psychological assessment requirement be recognized as satisfied by the treating pain physician's documented clinical evaluation and routine screening, with referral for separate evaluation reserved for cases where it is clinically indicated.

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Member briefing

The CMS Ambulatory Specialty Model (ASM): What Every ASPN Member Must Know Before January 1, 2027

The American Society of Pain and Neuroscience (ASPN) Office of Reimbursement & Regulatory Affairs has published a member briefing on the CMS Ambulatory Specialty Model (ASM) — a mandatory, two-sided risk payment model finalized October 31, 2025 that will directly affect thousands of interventional pain, anesthesiology, and PM&R physicians beginning January 1, 2027. Payment adjustments range from ±9% in Year 1 to ±12% by 2031, applied to all Medicare Part B services, with no opt-out for physicians in selected geographies who meet volume thresholds. Members in affected regions should verify their status immediately using the CMS ASM Participant Lookup Tool and take readiness steps before Summer 2026.

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Comment letter

ASPN challenges restrictive Medicare coverage determinations for peripheral nerve procedures

The American Society of Pain and Neuroscience (ASPN) has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) and five Medicare Administrative Contractors (MACs) opposing proposed Local Coverage Determinations (LCDs) that classify genicular radiofrequency ablation (RFA) and other peripheral nerve interventions as “experimental” or “investigational.” ASPN asserts that these procedures are evidence-supported, guideline-endorsed, and represent standard care for chronic pain management. The Society warns that the proposals would create unjust geographic disparities—granting access to beneficiaries in some states while denying identical patients in others—and violate CMS’s statutory obligation to ensure equitable coverage nationwide. ASPN urges CMS to withdraw the draft LCDs, maintain coverage for genicular and other peripheral nerve procedures consistent with published evidence and ASPN STEP Guidelines, and convene a national MEDCAC process to establish uniform policy that preserves patient access to safe, effective interventional pain therapies.

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Comment letter

ASPN responds to CMS proposed rule for Physician Fee Schedule (PFS) 2026

The American Society of Pain and Neuroscience (ASPN) has submitted formal comments on the Centers for Medicare & Medicaid Services’ (CMS) proposed 2026 Medicare Physician Fee Schedule (PFS) rule. While supporting increased reimbursement for office-based procedures, telehealth expansion, and chronic care management updates, ASPN strongly opposes certain value-based care provisions that could disadvantage smaller practices. The Society also calls for a taxonomy-based modifier to ensure fair reimbursement for pain specialists, greater transparency in CMS data and audit processes, and protections against efficiency adjustments that may reduce payments for pain procedures. ASPN emphasizes the need for policies that sustain independent practices, promote innovation, and preserve patient access to high-quality pain management care.

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Document cover: Carelon Proposed Clinical Appropriateness Guidelines and Criteria for Spinal Cord Stimulation (SCS) in Non-Surgical Low Back Pain

Formal response

Carelon Proposed Clinical Appropriateness Guidelines and Criteria for Spinal Cord Stimulation (SCS) in Non-Surgical Low Back Pain

The American Society of Pain and Neuroscience (ASPN) has submitted a formal response to Carelon’s proposed restrictions on spinal cord stimulation (SCS) for non-surgical low back pain. Backed by robust clinical evidence and expert consensus, ASPN urges Carelon to revise its policy to reflect modern pain management standards and ensure patients receive timely, effective care.

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Formal response

ASPN Response to BMJ's Clinical Practice Guideline on Chronic Spine Pain

The American Society of Pain & Neuroscience (ASPN) challenges the recent BMJ guideline that opposes interventional procedures for chronic spine pain. This response highlights significant methodological flaws, statistical errors, and bias within the BMJ publication, advocating for scientific integrity and patient access to effective pain management.

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Position statement

ASPN Position Statement: Appropriate Performance of Minimally Invasive Surgical Procedures

This ASPN position statement outlines the appropriate training, scope, and standards for performing minimally invasive surgical procedures of the spine and peripheral nerves. It emphasizes multidisciplinary collaboration, patient safety, and evidence-based practices.

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Advocacy & Policy

Competency-Based Training and Certification for Minimally Invasive Spine Interventions and Surgery

ASPN requests reconsideration of Humana and Cohere's psychological evaluation requirement for basivertebral nerve ablation

The CMS Ambulatory Specialty Model (ASM): What Every ASPN Member Must Know Before January 1, 2027

ASPN challenges restrictive Medicare coverage determinations for peripheral nerve procedures

ASPN responds to CMS proposed rule for Physician Fee Schedule (PFS) 2026

Carelon Proposed Clinical Appropriateness Guidelines and Criteria for Spinal Cord Stimulation (SCS) in Non-Surgical Low Back Pain

ASPN Response to BMJ's Clinical Practice Guideline on Chronic Spine Pain

ASPN Position Statement: Appropriate Performance of Minimally Invasive Surgical Procedures