Thank you to Patient Advocate & Researcher Deborah Duricka, PhD, for the below toolkit.
Full toolkit here: https://solvecfs.org/wp-content/uploads/2025/10/Patients_Allies_Multi-MAC_LCD_Comment_Packet.pdf
“Please add your voice to preserve access to chronic pain treatments involving peripheral nerve blocks (e.g. Stellate Ganglion Block).
Enshrining a blanket denial in Medicare coverage determinations would effectively deny care and hope to those in desperate need of both.”
— Deborah Duricka, PhD
Five out of seven Medicare contractors have proposed limiting coverage for nerve blocks and related procedures that people with ME/CFS, Long COVID, and other chronic conditions rely on to manage pain and function.
These proposed Local Coverage Determinations (LCDs) would deny access to peripheral nerve blocks, nerve ablation, and cryoneurolysis. These are interventions that help reduce reliance on opioids, decrease ER visits, and allow many patients to walk, sleep, or work with less pain. For example, Stellate Ganglion Blocks (SGB) are a treatment that some ME/CFS and Long COVID patients report has reduced their brain fog, fatigue, and autonomic symptoms like POTS or post-exertional crashes.
These changes go against CMS’s own stated goals of encouraging multi-modal pain management and reducing the use of opioids.
If finalized, these proposals won’t just affect Medicare patients. Private insurers often follow Medicare’s lead, which could put anyone using private insurance at risk of losing access to critical care.
Why This Matters to the ME/CFS and Long COVID Community
Patients with ME/CFS and Long COVID often experience complex chronic pain, migraine, neuropathic symptoms, and dysautonomia. Some of the procedures for which coverage may be denied are under investigation for their potential to improve fatigue, brain fog, and orthostatic intolerance.
While evidence is still emerging, patient experiences and preliminary studies show that these procedures may provide relief where few options exist. Limiting access now could close the door before we’ve even finished learning who might benefit.
What is at stake
Among other limitations, the following procedures will not be covered, using the language “It is not reasonable and necessary for therapeutic peripheral nerve blocks, peripheral nerve denervation from ablation (RFA) or cryoneurolysis for the treatment of”:
- Occipital nerve block and denervation
- Stellate ganglion block
- Trigeminal nerve block
- Suprascapular nerve block
- Thoracic nerve block
- Thoracic nerve denervation
- Genicular nerve blocks (GNB), cryoneurolysis or ablation
- Pudendal nerve block
- Digital nerve block
- Posterior tibial nerve block at the tarsal tunnel
- Ulnar nerve block
- Denervation of the trigeminal nerve for any diagnosis other than TN
- Any other peripheral nerves blocks, or denervation not listed above
Exceptions:
- Regional anesthetic block
- Acute surgical pain
- Pain related to malignancy refractory to medical management
Public comments matter! If you have received any of these treatments or others targeted in the proposals and think they ARE “reasonable and necessary”, please speak up. Below are step‑by‑step instructions and the right contact information for each MAC-specific LCD so you can submit your comment quickly.
How to Submit a Public Comment
Public comments are a crucial way to influence the final policy. You don’t need to be a Medicare recipient to weigh in. If you’ve received any of these procedures or believe they are medically necessary for people with chronic illness, your voice matters.
Step 1: Find Your Medicare Administrative Contractor (MAC)
Use the table below to identify your MAC based on your state, then read their proposed LCD by clicking the link in the MAC name.
Step 2: Submit Your Comment
Send an email to the listed address. Be sure to include the proposed policy number (e.g., “Comment on DL40261”) in your subject line. Use one of the templates at the bottom of this post to guide your message.
Medicare Contractor Contact Details
| MAC Contractor |
States/Territories Covered |
Comment Email |
| National Government Services (NGS) |
CT, ME, MA, NH, NY, RI, VT |
NGSDraftLCDComments@anthem.com |
| CGS Administrators, LLC |
AL, AR, CO, FL, GA, IL, IN, KY, LA, MS, NC, NM, OH, OK, PR, SC, TN, TX, VA, WV |
cmd.inquiry@cgsadmin.com |
| Noridian Healthcare Solutions, LLC |
AK, AZ, CA, HI, ID, MT, ND, NV, OR, SD, UT, WA, WY, Pacific Territories |
policydraft@noridian.com |
| WPS Government Health Administrators |
IA, KS, MO, NE |
policycomments@wpsic.com |
| Palmetto GBA |
AL, GA, NC, SC, TN, VA, WV |
A.Policy@palmettogba.com |
What to Say: Examples You Can Copy
- Put the correct DL number in your subject line (e.g., “Comment on DL40261”).
- Be specific about how these procedures affect function (walking, self‑care, work, sleep) and health care use (ER visits, opioid needs). Managers need to know that denying coverage will cost more in the long run.
- Use any of the examples below as-is or adapt them. Replace bracketed items with your details.
Short personal message (patients/caregivers)
Subject: Please Protect Access to Peripheral Nerve Blocks – Comment on Draft LCD [DL####]
Dear Medical Director,
I am a [patient/caregiver] living with [condition]. Peripheral nerve blocks and related procedures have been essential for [why it matters: mobility, sleep, work, fewer ER visits, avoiding opioids, etc.]. Before receiving [treatment], I experienced [symptoms] which have since improved, allowing me to [list things you can do now that you could not do before treatment]. If Medicare stops covering this procedure, I will lose access to the only treatment that allows me to work and care for my family. Please keep coverage for peripheral nerve blocks and recognize that these procedures are supported by clinical studies and decades of safe use.
Thank you for considering my experience.
[Name, city/state]
Evidence‑oriented message (patients & allies)
Subject: Comment on Draft LCD [DL####]: Maintain Access to Peripheral Nerve Blocks for Chronic Pain
Dear Medical Directors,
I urge you to revise the draft LCD to maintain coverage for peripheral nerve blocks and related treatments when my medical provider considers them medically necessary. These procedures can reduce pain, improve function, and reduce reliance on opioids. The draft applies standards designed for medications (large, industry‑funded RCTs) to procedures, for which there is little financial incentive to conduct large trials. As a result, the evidence base includes smaller, pragmatic studies and real‑world experiences that still show meaningful patient benefit.
Please preserve patient access with appropriate safeguards (documentation of indication, image guidance when necessary, reasonable frequency limits) rather than categorical noncoverage.
Sincerely,
[Name], [role/affiliation, optional]
Clinician/Ally message (clinicians, nonprofits, community leaders)
Subject: Comment on Draft LCD [DL####]: Patient‑Centered Coverage for Peripheral Nerve Blocks
Dear Medical Directors,
As a [clinician/advocate/community leader], I’ve seen patients regain daily function and reduce opioid use thanks to properly selected peripheral nerve blocks and percutaneous denervation. The draft LCD would curtail these options except for a narrow set of diagnoses.
Please consider: (1) allowing coverage for peripheral nerve blocks and denervation when medically necessary and supported by clinical judgment and documentation; (2) aligning coverage with existing multidisciplinary guidelines; and (3) avoiding one‑size‑fits‑all exclusions that are not reflective of patient heterogeneity.
Respectfully,
[Name], [credentials/organization]
Additional Action Step: Contact Your Members of Congress
You can also reach out to your Members of Congress and ask them to follow up with the Medicare Contractors on your behalf:
To find your representative (Senators and Congresspeople), go to the following website and enter your location:
https://www.congress.gov/members/find-your-member
Phone Script
Hi, my name is [Your Name], and I live in [City, State]. I’m calling to ask [Senator/Representative NAME] to speak out against proposed Medicare policies that would restrict access to peripheral nerve blocks.
These procedures are helping people with ME/CFS and Long COVID manage pain, fatigue, and brain fog. Cutting coverage now could also block access for anyone who uses private insurance, as private insurers follow Medicare’s lead.
Please ask CMS and the Medicare contractors to protect access while research continues. Thank you!
Email Template
Subject: Please Protect Access to Emerging ME/CFS & Long COVID Treatments
Dear [Senator/Representative NAME],
I’m writing to urge you to oppose proposed Medicare policies that would deny coverage for peripheral nerve blocks which are helping some people with ME/CFS and Long COVID manage serious symptoms.
These proposals could eliminate access not just for Medicare patients, but across the board. Please contact CMS and ask them to reconsider these restrictions and preserve access while more research is ongoing.
Thank you,
[Your Name]
[City, State]
Speak Up to Protect Access to an Emerging ME/CFS Treatment
Thank you to Patient Advocate & Researcher Deborah Duricka, PhD, for the below toolkit.
Full toolkit here: https://solvecfs.org/wp-content/uploads/2025/10/Patients_Allies_Multi-MAC_LCD_Comment_Packet.pdf
“Please add your voice to preserve access to chronic pain treatments involving peripheral nerve blocks (e.g. Stellate Ganglion Block).
Enshrining a blanket denial in Medicare coverage determinations would effectively deny care and hope to those in desperate need of both.”
— Deborah Duricka, PhD
Five out of seven Medicare contractors have proposed limiting coverage for nerve blocks and related procedures that people with ME/CFS, Long COVID, and other chronic conditions rely on to manage pain and function.
These proposed Local Coverage Determinations (LCDs) would deny access to peripheral nerve blocks, nerve ablation, and cryoneurolysis. These are interventions that help reduce reliance on opioids, decrease ER visits, and allow many patients to walk, sleep, or work with less pain. For example, Stellate Ganglion Blocks (SGB) are a treatment that some ME/CFS and Long COVID patients report has reduced their brain fog, fatigue, and autonomic symptoms like POTS or post-exertional crashes.
These changes go against CMS’s own stated goals of encouraging multi-modal pain management and reducing the use of opioids.
If finalized, these proposals won’t just affect Medicare patients. Private insurers often follow Medicare’s lead, which could put anyone using private insurance at risk of losing access to critical care.
Why This Matters to the ME/CFS and Long COVID Community
Patients with ME/CFS and Long COVID often experience complex chronic pain, migraine, neuropathic symptoms, and dysautonomia. Some of the procedures for which coverage may be denied are under investigation for their potential to improve fatigue, brain fog, and orthostatic intolerance.
While evidence is still emerging, patient experiences and preliminary studies show that these procedures may provide relief where few options exist. Limiting access now could close the door before we’ve even finished learning who might benefit.
What is at stake
Among other limitations, the following procedures will not be covered, using the language “It is not reasonable and necessary for therapeutic peripheral nerve blocks, peripheral nerve denervation from ablation (RFA) or cryoneurolysis for the treatment of”:
Exceptions:
Public comments matter! If you have received any of these treatments or others targeted in the proposals and think they ARE “reasonable and necessary”, please speak up. Below are step‑by‑step instructions and the right contact information for each MAC-specific LCD so you can submit your comment quickly.
How to Submit a Public Comment
Public comments are a crucial way to influence the final policy. You don’t need to be a Medicare recipient to weigh in. If you’ve received any of these procedures or believe they are medically necessary for people with chronic illness, your voice matters.
Step 1: Find Your Medicare Administrative Contractor (MAC)
Use the table below to identify your MAC based on your state, then read their proposed LCD by clicking the link in the MAC name.
Step 2: Submit Your Comment
Send an email to the listed address. Be sure to include the proposed policy number (e.g., “Comment on DL40261”) in your subject line. Use one of the templates at the bottom of this post to guide your message.
Medicare Contractor Contact Details
What to Say: Examples You Can Copy
Short personal message (patients/caregivers)
Subject: Please Protect Access to Peripheral Nerve Blocks – Comment on Draft LCD [DL####]
Dear Medical Director,
I am a [patient/caregiver] living with [condition]. Peripheral nerve blocks and related procedures have been essential for [why it matters: mobility, sleep, work, fewer ER visits, avoiding opioids, etc.]. Before receiving [treatment], I experienced [symptoms] which have since improved, allowing me to [list things you can do now that you could not do before treatment]. If Medicare stops covering this procedure, I will lose access to the only treatment that allows me to work and care for my family. Please keep coverage for peripheral nerve blocks and recognize that these procedures are supported by clinical studies and decades of safe use.
Thank you for considering my experience.
[Name, city/state]
Evidence‑oriented message (patients & allies)
Subject: Comment on Draft LCD [DL####]: Maintain Access to Peripheral Nerve Blocks for Chronic Pain
Dear Medical Directors,
I urge you to revise the draft LCD to maintain coverage for peripheral nerve blocks and related treatments when my medical provider considers them medically necessary. These procedures can reduce pain, improve function, and reduce reliance on opioids. The draft applies standards designed for medications (large, industry‑funded RCTs) to procedures, for which there is little financial incentive to conduct large trials. As a result, the evidence base includes smaller, pragmatic studies and real‑world experiences that still show meaningful patient benefit.
Please preserve patient access with appropriate safeguards (documentation of indication, image guidance when necessary, reasonable frequency limits) rather than categorical noncoverage.
Sincerely,
[Name], [role/affiliation, optional]
Clinician/Ally message (clinicians, nonprofits, community leaders)
Subject: Comment on Draft LCD [DL####]: Patient‑Centered Coverage for Peripheral Nerve Blocks
Dear Medical Directors,
As a [clinician/advocate/community leader], I’ve seen patients regain daily function and reduce opioid use thanks to properly selected peripheral nerve blocks and percutaneous denervation. The draft LCD would curtail these options except for a narrow set of diagnoses.
Please consider: (1) allowing coverage for peripheral nerve blocks and denervation when medically necessary and supported by clinical judgment and documentation; (2) aligning coverage with existing multidisciplinary guidelines; and (3) avoiding one‑size‑fits‑all exclusions that are not reflective of patient heterogeneity.
Respectfully,
[Name], [credentials/organization]
Additional Action Step: Contact Your Members of Congress
You can also reach out to your Members of Congress and ask them to follow up with the Medicare Contractors on your behalf:
To find your representative (Senators and Congresspeople), go to the following website and enter your location:
https://www.congress.gov/members/find-your-member
Phone Script
Hi, my name is [Your Name], and I live in [City, State]. I’m calling to ask [Senator/Representative NAME] to speak out against proposed Medicare policies that would restrict access to peripheral nerve blocks.
These procedures are helping people with ME/CFS and Long COVID manage pain, fatigue, and brain fog. Cutting coverage now could also block access for anyone who uses private insurance, as private insurers follow Medicare’s lead.
Please ask CMS and the Medicare contractors to protect access while research continues. Thank you!
Email Template
Subject: Please Protect Access to Emerging ME/CFS & Long COVID Treatments
Dear [Senator/Representative NAME],
I’m writing to urge you to oppose proposed Medicare policies that would deny coverage for peripheral nerve blocks which are helping some people with ME/CFS and Long COVID manage serious symptoms.
These proposals could eliminate access not just for Medicare patients, but across the board. Please contact CMS and ask them to reconsider these restrictions and preserve access while more research is ongoing.
Thank you,
[Your Name]
[City, State]