February 4, 2021 Meredith Loveless, MD via Email: meredith.loveless@cgsadmin.com Neil Sandler, MD via Email: neil.sandler@cgsadmin.com CGS Administrators, LLC 2 Vantage Way – Metro Center Nashville, TN 37228 Dear Drs. Loveless and Sandler: The undersigned medical specialty societies, comprising physicians who utilize and/or perform interventional spine procedures to accurately diagnose and treat patients suffering from spine pathologies, would like to take this opportunity to express our strong support for coverage of epidural injections for chronic pain management, and provide a detailed explanation of their importance to Medicare patients’ quality of life. Our societies have a strong record of working to eliminate fraudulent, unproven, and inappropriate procedures. At the same time, we are equally committed to assuring that appropriate, effective, and responsible treatments are preserved. Significant relief of radicular neck and back pain, improved quality of life, with restoration of function and return to work, as well as decreased utilization of other healthcare resources is an outcome that should be readily available to patients covered by Medicare. When epidural injections are performed in a disciplined, responsible manner, they achieve outcomes that are clinically, socially, and economically worthwhile. SELECTIVE SPINAL NERVE BLOCKS Selective spinal nerve blocks (SSNBs) use a small amount of anesthetic injected via a transforaminal approach to anesthetize a specific spinal nerve. SSNBs are diagnostic tools used to evaluate a patient’s anatomical level and/or source of radicular pain. They are often used in surgical planning and decision-making.1 EPIDURAL STEROID INJECTIONS Epidural steroid injections (ESIs) are validated treatments for radicular pain. Many recently published, high profile systematic reviews found that ESIs may be more effective compared to placebo injections in reducing leg pain and disability and were recommended for persistent severe radicular pain, with some studies questioning the advantage of adding steroids to local anesthetic injections.2-4 These reviews provide excellent information, but have not separately assessed the outcomes of ESIs for different diagnoses and techniques, with goals of identifying patient populations and techniques for which ESIs have a greater likelihood of positive outcomes. Several high-quality systematic reviews have been published that address these issues by reviewing the body of evidence related to cervical and lumbar epidural steroid injections,5-8 with meticulous stratification by selection criteria and procedural technique. These reviews are attached and present the outcomes