Protecting Access to Headache Care: AHDA Submits Comments on Proposed Medicare Coverage Restrictions
Many in our community have reached out with confusion and concern about a series of new proposed Medicare policies that could limit access to procedures commonly used to treat migraine, cluster headache, occipital neuralgia, and other severe headache disorders.
Last week, the Alliance for Headache Disorders Advocacy (AHDA) submitted detailed comments to the Centers for Medicare & Medicaid Services (CMS) and several regional contractors opposing these proposed restrictions. Below, we explain what is happening, why it matters, and what AHDA is doing to protect access to care for people living with disabling headache and pain conditions.
What Are LCDs?
Medicare does not always make national decisions about what is covered. Instead, it often leaves those decisions to regional companies called Medicare Administrative Contractors (MACs). Each MAC issues what is known as a Local Coverage Determination (LCD), which defines what treatments and procedures will be reimbursed under Medicare in that region.
When a MAC proposes a change, it publishes a Proposed LCD and opens a public comment period. During that time, clinicians, researchers, and patients can submit feedback before the policy is finalized. These comments are an important part of the process and can influence whether a policy is changed or withdrawn.
What Happened
In late 2025, several MACs across the country; WPS, National Government Services (NGS), CGS Administrators, Noridian, and Palmetto GBA, released nearly identical Proposed LCDs titled “Peripheral Nerve Blocks and Procedures for Chronic Pain.”
These proposals would classify peripheral nerve blocks, such as occipital and trigeminal nerve blocks, as “not medically reasonable and necessary” for most headache disorders, including migraine, cluster headache, and occipital neuralgia.
In practical terms, this means many Medicare patients could lose coverage for these simple, low-risk, in-office procedures that provide relief when medications fail, are not tolerated, or are unsafe. For some patients, especially older adults or those who are pregnant, these procedures are among the few safe options available.
Why This Matters
Peripheral nerve blocks are minimally invasive procedures in which a small amount of local anesthetic is injected near a nerve to reduce pain and inflammation. They are supported by research, carry very low risk, and are often transformative for people with severe or treatment-resistant headache disorders.
These procedures can:
- Provide rapid relief from prolonged migraine or cluster headache attacks
- Help diagnose occipital neuralgia and other nerve-related pain conditions
- Reduce reliance on emergency departments and high-risk medications
- Support function, employment, and independence for people living with chronic pain
Limiting coverage for these procedures would not only reduce access for headache patients, but could also affect many others living with neuropathic and chronic pain. This is part of a larger trend of coverage restrictions that could harm both the headache and broader pain communities.
What AHDA Did
The Alliance for Headache Disorders Advocacy coordinated a detailed, evidence-based response with input from clinicians, researchers, and patient organizations.
In our official comments submitted to the relevant MACs, we:
- Opposed the proposed coverage restrictions, citing lack of clinical justification
- Provided peer-reviewed evidence demonstrating that occipital and trigeminal nerve blocks improve pain control, reduce emergency department visits, and help prevent disability
- Explained that these procedures are part of the diagnostic criteria for occipital neuralgia
- Highlighted that nerve blocks are safe, cost-effective, and essential for patients who do not respond to or cannot tolerate medications
- Emphasized that limiting access would worsen health disparities, particularly for women, older adults, and underserved communities
- Urged CMS and its contractors to withdraw or revise the policies
AHDA also alerted clinicians, researchers, and advocates across the country to submit their own comments during the open periods.
What’s Next
The comment periods for these policies have now closed for all MACs except WPS, whose public comment period remains open through November 22, 2025. AHDA will continue to monitor this situation closely and will update our community if and when responses are received.
We are also watching for additional proposed LCDs that could affect access to headache or pain-related care. Our goal is to ensure that lawmakers, regulators, and insurance companies understand both the science and the real-world consequences of restricting coverage for these procedures.
How You Can Get Involved
Access to care doesn’t change without advocacy. If you want to learn how to use your voice to protect access for people living with migraine and other headache disorders, consider applying to Headache on the Hill, our annual event where patients, caregivers, clinicians, and researchers come together to meet with members of Congress and advocate for better federal policies. Applications are open until December 10th and are being processed on a rolling basis. Apply today!