Dear AUGS Members,

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.