Save OMT: Comment on proposed changes to local coverage determination

Posted 12:00 AM by

Updated Aug. 16

Thank you to all the osteopathic physicians, medical students and patients who contributed comment letters opposing the proposed LCD change in Connecticut, Illinois, Maine, Massachusetts, Minnesota, New Hampshire, New York, Rhode Island, Vermont and Wisconsin. 

During this campaign, the American Osteopathic Association collected 5,024 letters via email and the website. To put that in perspective, the campaign to respond to MACRA, which impacts osteopathic physicians in all 50 states, only generated 3,918 comment letters.

"Why did we not start a petition asking the President to intervene?"
A petition would have been a poor tactical choice for this issue. The odds of us reaching the 100,000 signatures necessary were extraordinarily low. With only 10 states being impacted and a short period of time for comments, focusing our resources on gathering petition signatures from the 80 percent of the nation not impacted by this LCD would have dramatically diminished our ability to organize those in the 10 impacted states. More importantly, the AOA is already in discussions with the highest levels of the Administration on this issue.

"Why didn't the AOA directly ask me to participate in the campaign?"
Effective advocacy campaigns deliver the right message, from the right messenger, at the right point in the process. The AOA values your voice and passion. On this issue, the voice of a physician from Vermont is more powerful than the voice of a physician from Idaho. Too many voices from non-impacted states can drown out the voices of those in the 10 impacted states and harm the campaign. Think of it like this: If you are a resident of Arizona and write a member of Congress from Florida about an issue you are passionate about, does the member from Florida consider your opinion? For this issue, the right messengers were DOs, OMS, or patients from the 10 impacted states

What's next?
The AOA will use the comment letters to reinforce its position in discussions with NGS, CMS, and the Administration. CMS has included potential changes to OMT in the 2017 proposed physician fee schedule, and the AOA will ask the entire osteopathic community across all states to help support their response.



Updated Aug. 11

As of Aug. 10, the American Osteopathic Association's advocacy center has received more than 3,000 comment letters. Only 1,396 (45 percent) of the letters are from residents of the 10 states immediately affected by the pending change to their local coverage determination (Connecticut, Illinois, Maine, Massachusetts, Minnesota, New Hampshire, New York, Rhode Island, Vermont and Wisconsin). While comment letters from those outside the 10 affected states are helpful to demonstrate the broad scope of support and to explain the potential widespread impact, letters from the 10 affected states carry the most weight during this process. 

Thanks to your action, the AOA is forwarding more than 400 letters each day to the National Government Services to keep the pressure on.

The deadline for comment letters is Saturday, Aug. 13, and the AOA team hopes to receive a total of 1,750 letters from the 10 affected states.



Original post, July 18:

National Government Services (NGS), a regional Medicare carrier in 10 states—Illinois, Minnesota, Wisconsin, Connecticut, New York, Massachusetts, New Hampshire, Vermont, Maine and Rhode Island—has announced that they intend to change the local coverage determination (LCD) DL33616, which dictates coverage indications and limitations/medical necessity for OMT.

The proposed changes have the potential to negatively limit our reimbursement and could affect patient treatments and outcomes at a time when there is a need for nonpharmacologic treatment options to improve function and decrease pain. Although the current changes affect only 10 states, the rule could quickly spread across the country, adopted by other Medicare contractors and private insurers. 

What Is AAO Doing?
Some of you have reached out to the AAO and the Osteopathic Medical Economics Committee (OMEC) regarding the recent announcement and have asked what is being done to address this and what can you do to help. The AAO leadership has been coordinating its efforts with the AOA and some of the state organizations in response to NGS. The efforts have been made to bring about a resolution that serves all DOs and our patients.

At the most recent meeting of the carrier advisory board in Waltham, Massachusetts, on June 21, 2016, members of the AOA leadership, AAO OMEC and the Maine Osteopathic Association (MOA), as well as others, spoke to the need to revise the proposed changes and to protect our ability to practice OMT and receive fair reimbursement. These efforts have been ongoing since that time, and public comments are being accepted until Aug. 13, 2016.

During this time, we have continued to work to coordinate our responses with AOA leaders, including AOA President Boyd R. Buser, DO, FACOFP. To coordinate the public response in a unified manner, the AOA has suggested the following:

It is important for comment letters, as much as is possible, to go through a centralized submission process for two key reasons:

  1. It allows for the staging of submissions, so there can be a steady flow throughout the comment period which has already begun and finalizes on Aug. 13.
  2. It allows contact information to be captured so personal follow-up can take place and requests for additional actions be initiated at key moments.

To maximize effectiveness, the AOA is focusing on AOA member physicians who practice in the 10 affected states. Those AOA members will receive a letter from AOA President Buser asking them to return two petition cards expressing their opposition to the draft LCD. The AOA will follow up with each person who returns a petition card to ask them to take additional advocacy actions.

What Can You DO?
All physicians, osteopathic medical students and patients are encouraged to submit comment letters online at Or you can email your letter directly to  

Download the AOA high-level talking points to help you draft your comment letter. The document also includes a red-lined version of the LCD. The edits you see there are not the AOA’s proposed changes; they are the NGS’s changes.

The OMEC and the AAO encourage all DOs to write in support and submit your response during the open comment period.

Additionally, please notify AAO OMEC of any related issues that arise in your state so that an appropriate response can be made.