Key Takeaways
- Five Medicare Administrative Contractors have proposed LCDs that would eliminate coverage for most peripheral nerve block and denervation procedures for chronic pain.
- The proposals would leave coverage largely intact for facet joint interventions, epidural injections, and three narrowly defined exceptions.
- Public comment periods closed in November 2025, and none of the five MACs has issued a final determination.
- The proposed changes apply only in the states covered by the five MACs involved, not nationwide.
- At least one commercial payer has already referenced the proposed LCDs in its own coverage policy.
Five Medicare Administrative Contractors (MAC) proposed new coverage policies in 2025 that would eliminate Medicare payment for most peripheral nerve block and denervation procedures used to treat chronic pain. The public comment periods closed in November 2025. As of this writing, none of the five MACs has issued a final determination, and the proposal remains what it was 10 months ago: unresolved. For pain management practices in the affected states, that uncertainty is the operating reality right now.
What the Proposed LCDs Would Actually Change
The proposed policies would reclassify most peripheral nerve block and denervation procedures for chronic pain as not reasonable and necessary, the Medicare standard a service has to meet to remain covered. Coverage would stay largely intact for two broad categories, facet joint interventions and epidural injections, plus a narrow set of specific exceptions with defined limits. Everything else in the peripheral nerve block category would move to non-covered status. The American Academy of Pain Medicine has published a full summary of the proposal with links to each MAC’s specific coverage document.
The narrow exceptions that would remain covered:
- Radiofrequency neurolysis for trigeminal neuralgia
- Corticosteroid injections for median neuropathy at the wrist, up to three injections
- Corticosteroid injections for Morton’s neuroma, up to two injections
Procedures that would lose coverage under the proposal include occipital nerve blocks, stellate ganglion blocks, suprascapular nerve blocks, genicular nerve blocks, pudendal nerve blocks, and posterior tibial nerve blocks, along with the radiofrequency ablation procedures performed alongside many of them.
Which States and Practices Are Affected
The five MACs behind these proposals, CGS, NGS, Noridian, Palmetto, and WPS, together administer Medicare claims in 24 states. Facet joint and epidural procedures are unaffected regardless of jurisdiction, since those categories remain covered under the proposal as written.
The MACs and the states they cover:
- NGS: Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, Connecticut, New York, New Jersey
- Noridian: Alaska, Arizona, California, Hawaii, Nevada, Oregon, Washington
- Palmetto: Virginia, North Carolina, South Carolina, West Virginia
- CGS: Kentucky, Ohio
- WPS: Michigan, Wisconsin, Illinois
A practice outside these 24 states isn’t directly subject to this specific proposal, but the policy is worth watching regardless of jurisdiction. Coverage decisions made by one MAC sometimes get adopted by others, and at least one commercial payer, Blue Cross NC, has already referenced the proposed LCDs in its own coverage policy for genicular nerve blocks.
Where the Process Stands Right Now
The proposed LCDs have moved through a public process, but not toward resolution (a full account of the standoff is available from Becker’s ASC Review):
- 2025: CGS, NGS, Noridian, Palmetto, and WPS released proposed LCDs restricting peripheral nerve block coverage
- Nov. 8, 2025: public comment period closed for CGS, NGS, Noridian, and Palmetto
- Nov. 22, 2025: public comment period closed for WPS
- Nov. 2025: the AMA House of Delegates adopted a resolution opposing the proposed LCDs, backed by the American Academy of Pain Medicine and several other pain societies
- December 2025: the AMA sent a formal letter to CMS Administrator Mehmet Oz urging withdrawal or delay of the proposals
- January 2026: leaders from the Pain Medicine Coalition met with MAC representatives to discuss the proposal directly
- August 2026: the peer-reviewed journal Pain Medicine published commentary on the proposal’s clinical and policy implications, evidence the issue remains active and unresolved
None of the five MACs has published a final LCD. Until one does, existing coverage policy stays in effect in each jurisdiction.
What Happens If the Policies Are Finalized
If a MAC finalizes its proposed LCD as written, claims for the affected nerve block and denervation procedures would be denied as not reasonable and necessary in that MAC’s jurisdiction, regardless of documentation quality. This is a coverage determination. The usual fixes for a denial, better modifier use, more complete operative notes, wouldn’t change that outcome.
Practices in the affected states would likely need to shift toward the treatments that remain covered (facet joint interventions, epidural injections, the three narrow exceptions) and have direct conversations with patients about self-pay or Advance Beneficiary Notice options for now-excluded procedures. Given that Blue Cross NC has already pointed to the proposed LCDs in a genicular nerve block policy, a final Medicare decision could also shape how commercial payers approach these procedures well beyond Medicare’s own jurisdictions.
What Pain Management Practices Can Do While This Is Pending
Nothing about the proposal requires action yet, since none of it is final. A few things are worth doing anyway. Documentation that clearly supports medical necessity remains valuable no matter how the LCDs resolve, since the clinical need for these procedures doesn’t disappear if the policy changes, it becomes a documentation and alternative-pathway question instead. Watching for movement in a practice’s specific MAC jurisdiction, a final LCD, a further delay, a withdrawal, matters more than tracking every MAC nationally. Practices with a stake in the outcome can also follow the advocacy already underway through the American Academy of Pain Medicine, ASRA Pain Medicine, and state and specialty pain societies.
Staying Ahead of Policy Changes Like This One
Coverage shifts like this one are exactly what a pain management billing partner should already be tracking on a practice’s behalf. PGM’s pain management billing team monitors LCD and NCD updates across payer jurisdictions as part of standard service, so clients in the affected states aren’t finding out about a final determination after the fact.
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Frequently Asked Questions About Pain Management Nerve Block Coverage
Which states are affected by the proposed nerve block coverage changes?
The proposal applies in the 24 states covered by five Medicare Administrative Contractors: CGS (Kentucky, Ohio), NGS (Maine, New Hampshire, Vermont, Massachusetts, Rhode Island, Connecticut, New York, New Jersey), Noridian (Alaska, Arizona, California, Hawaii, Nevada, Oregon, Washington), Palmetto (Virginia, North Carolina, South Carolina, West Virginia), and WPS (Michigan, Wisconsin, Illinois). Practices outside these states aren’t directly subject to this specific proposal.
Are facet joint injections and epidural injections affected by this proposal?
No. The proposed LCDs leave facet joint interventions and epidural injections largely untouched. The restrictions target other peripheral nerve block and denervation procedures, such as occipital, stellate ganglion, genicular, and pudendal nerve blocks.
Has Medicare made a final decision on the peripheral nerve block LCDs?
Not as of this writing. Public comment periods closed in November 2025, and none of the five MACs involved has published a final LCD. Existing coverage policy remains in effect in each jurisdiction until that changes.
Should a practice change its billing now, before a final decision is made?
Not based on the proposal alone. Since none of the LCDs are final, current coverage rules still apply. The more useful step right now is confirming documentation supports medical necessity under existing policy and watching for updates specific to a practice’s own MAC.
Could commercial payers adopt similar nerve block coverage restrictions?
It’s possible. Blue Cross NC has already referenced the proposed Medicare LCDs in a coverage policy for genicular nerve blocks, which suggests commercial payers are watching this process too, independent of what Medicare ultimately decides.