Click Here to Submit Your Public Comment to CMS

Dear Physician/Healthcare Provider,

We write to you today to ask for your honest professional opinion. Several days ago, the Centers for Medicare and Medicaid Services (CMS) issued a “National Coverage Analysis” notice seeking public comment on the effectiveness of Transcutaneous Electrical Nerve Stimulation for Chronic Low Back Pain. The CMS notice refers to a clinical study published in 2010 that concludes with a negative recommendation for the use of TENS for treatment of chronic low back pain.

It appears from the reference to this single study that CMS intends to modify or possibly eliminate Medicare coverage of TENS devices for any diagnosis related to chronic low back pain. We know that there are a multitude of clinical studies that contradict those conclusions, as well as a multitude of studies that support those conclusions or are inconclusive. The most consistent finding in all of the available studies is that more large scale, well designed clinical studies are required to provide true evidence based medical decisions about the effectiveness of TENS for chronic pain management. Zynex Medical supports the need for more appropriate clinical research but we also believe that more accurate and readily available information can be derived from each individual physician’s experience and that of their own patient group.


Medicare currently requires a 30 or 60 day rental “trial” period for a TENS device, at which time the patient and physician must determine if the device is an effective adjunct for pain management. When a physician and patient have mutually determined that the therapy is beneficial, and the physician signs a Medicare “Certificate of Medical Necessity”, then Medicare will allow for the purchase of a TENS device, as well as the purchase of any necessary supplies on an ongoing basis such as electrodes and batteries. TENS is not effective for every patient, but neither are alternative and more costly interventions such as narcotics, NSAID’s, and surgery. Many thousands of patients and physicians have determined that TENS is an effective adjunct for pain management.

The apparent CMS effort to limit the ability of patients and physicians to make medical decisions on the most effective pain management therapy should be a concern to all. There is a limited 30 day window open, ending on 10/13/2011, to make a public comment. We ask that you take a few minutes in your busy schedule to submit a public comment to CMS by clicking on the link below or typing in the web address in your internet browser:

Click Here to Submit Your Public Comment to CMS

We believe your honest medical opinion and that of your patients is the most important message that CMS can receive about this issue. Please contact me for any questions.

Dave Empey Compliance Officer or (800) 495-6670 ext. 3033