Member call to action for legislation allows constituents to advocate for policies, stay informed about upcoming changes in the law, and ensure their voice is heard by lawmakers. They are an important tool in our advocacy efforts as legislators need and want to hear from their constituents.
Comment on Draft Medicare LCDs for Botulinum Toxin by May 15
Five Medicare Administrative Contractors — Noridian, WPS, NGS, CGS, and Palmetto — have released draft Local Coverage Determinations (LCDs) that would change how botulinum toxin injections are covered, including for urogynecologic indications. The proposed policies include restrictions on dose escalation and impose administrative and treatment barriers that could meaningfully affect how we care for our patients.
The public comment period closes May 16, 2026, for all contractors except CGS, for which the comment period closes June 6, 2026. We need urogynecologists to weigh in.
AUGS has prepared draft comments outlining our concerns, which you can review here and adapt for your own submission. Personal letters from practicing physicians carry significant weight with MACs — far more than organizational comments alone — so we strongly encourage you to submit your own.
How to submit:
To submit comments, please click the link for the draft LCD applicable to your MAC/jurisdiction below. On the Medicare Coverage Database page, select “Submit Public Comment.” This should open a pre-addressed email to the MAC’s designated comment mailbox. Please attach your comment letter or paste your comments into the body of the email and submit before the applicable deadline.
| MAC | Jurisdiction | States | Draft LCD |
| CGS | J15 | KY, OH | DL39857 |
| NGS | J6 / JK | CT, IL, MA, ME, MN, NH, NY, RI, VT, WI | DL39832 |
| Noridian | JE | CA, HI, NV, American Samoa, Guam, Northern Mariana Islands | DL35170 |
| Noridian | JF | AK, AZ, ID, MT, ND, OR, SD, UT, WA, WY | DL35172 |
| Palmetto | JJ / MM | AL, GA, NC, SC, TN, VA, WV | DL39836 |
| WPS | J5 / J8 | IA, IN, KS, MI, MO, NE | DL39909 |
While AUGS will be submitting comments as an organization, even a short, specific comment from a practicing urogynecologist makes a difference. Please don’t assume someone else will speak for our subspecialty — this is exactly the moment our voices matter most.
Thank you for your advocacy.
Calls to Action:
Volunteer to be a Reviewer: The Center for Scientific Review (CSR) reviews three quarters of all NIH applications and virtually all submitted R01s. Having an increased presence of Urogynecologists serving as reviewers will ensure the development of a more comprehensive knowledge base on Urogynecologic conditions.
Recent Action Alerts
- Comment on Draft Medicare LCDs for Botulinum Toxin
- Women First Research Coalition Action Alert on NIH Funding
- HHS Reorganization
- Deregulation Request for Information
- Contact Your Representative Regarding NIH Funding Indirect Costs
- Tell Your Representative to Co-Sponsor H.R. 10073 and Stop the Medicare Payment Cut!
