Submit Comments to CMS

CMS Open Comment Period on Oxygen for Cluster – Proposed NCD

Proposed Decision Memo for Home Use of Oxygen and Home Oxygen Use to Treat Cluster Headaches (CAG-00296R2)

Deadline: July 31, 2021 11:59PM EST

WHAT: The Centers for Medicare and Medicaid Services (CMS) has initiated a 30-day review of their Proposed Decision Memo for home-use oxygen to treat cluster headaches (CAG-00296R2). Use of high-flow oxygen is proven to be the safest and most effective way to abort a cluster headache attack, however CMS policy has long denied coverage for home-use oxygen.

Through a lengthy multiyear process AHDA and our member organizations submitted a formal appeal of the National Coverage Determination for the CMS policy. CMS announced their proposed revision to this policy on July 2, 2021. The agency is asking for feedback to hear if this change is what the public is looking for or if change is needed before they make this the new active/final policy.

We are asking Americans living with cluster headache, caregivers, health care providers to participate in this open comment period.

WHY: CMS’s determination affects not only those who are of retirement age, but also those who receive social security disability benefits. CMS needs to hear from those most impacted by this policy change.

WHEN: Deadline is July 31, 2021 at 11:59PM ET.

HOW: The reference guide on this page has information you should consider including in your comments to CMS.

Note: All comments submitted to CMS will be posted publicly on the CMS website (select radio button for 7/2/21 – 8/1/21 comments). Only share information you are comfortable with being posted online.  

QUESTIONS? The Alliance for Headache Disorders Advocacy (AHDA) is organizing responses from those living with cluster, caregivers, health care professionals and the headache community at large during this Public Comment period. If you have questions, please email