07/09/2023

We Need Your Help to Challenge CGS Proposal to Make MIGS Investigational

Recently, CGS Administrators published a proposed local coverage determination policy on micro-invasive glaucoma surgery (MIGS) that considers some procedures, including adult goniotomy and canaloplasty, to be “investigational.”

Medicare typically does not pay for investigational or experimental treatments.

The OOS is concerned that CGS’ proposed policy states that the MIGS procedures below are considered investigational in patients over age 18 for glaucoma management:

• Goniotomy or ab interno trabecular bypass surgery
• Viscocanaloplasty
• Canaloplasty in combination with trabeculotomy ab interno
• Gonioscopy-assisted transluminal trabeculotomy
• Ab Interno Canaloplasty
• Cyclophotocoagulation
  
  

The OOS has submitted comments and now we need Ohio ophthalmologists to do the same. To submit personal comments to CGS, please email cmd.inquiry@cgsadmin.com  by July 29, 2023.

Be sure to include “Public Comment for Proposed LCD - Micro-Invasive Glaucoma Surgery (MIGS) (DL37578)” in the subject line.

Due to online security requirements, CGS is unable to accept encrypted emails, compressed attachments, and links. Comment letters are accepted as MS Word and/or Adobe PDF attachments.                 

 Key points that you may choose to include are:

• There is extensive published data and clinical experience over more than 10 years using MIGS, including goniotomy and canaloplasty to treat glaucoma.
  
  
• Patients with glaucoma, which disproportionately affects Black and Hispanic patients, need access to a range of surgical procedures.
  
  
• Trabecular meshwork stents have an important role in treating patients with glaucoma and coverage for standalone trabecular stents under CPT code 0671T is appreciated.
  
  
• There are some patients for whom treatment with medications is inadequate and their glaucoma is not at a stage requiring more invasive procedures such as trabeculectomy and tube shunts. For these patients, MIGS help preserve quality of life and reduce total costs to the healthcare system.
  
  
• Cyclophotocoagulation can be vision-saving in patients with no other options and decades of literature evidence support its efficacy, thus it should not be considered investigational.
  
  
• To ensure that Medicare beneficiaries with glaucoma have meaningful access to these transformative procedures, the draft LCD should be revised to include coverage for:
  • Goniotomy or ab interno trabecular bypass surgery
  • Viscocanaloplasty
  • Canaloplasty in combination with trabeculotomy ab interno
  • Gonioscopy-assisted transluminal trabeculotomy
  • Ab Interno Canaloplasty
  • Cyclophotocoagulation