Submit Comments to CMS

CMS Open Comment Period on Oxygen for Cluster

National Coverage Analysis (NCA) Tracking Sheet for Home Use of Oxygen and Home Oxygen Use to Treat Cluster Headaches (CAG-00296R2)

Deadline: September 16, 2020 

WHAT: The Centers for Medicare and Medicaid Services (CMS) has initiated a 30-day review of Home Oxygen Use 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 denies coverage for home-use oxygen.

AHDA and our member organizations submitted a formal appeal of the National Coverage Determination for the CMS policy in January 2019. As a result of that appeal, the policy is now up for reconsideration. 

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. In addition, many insurance companies also deny oxygen therapy for cluster attacks, citing CMS’s current policy. 

WHEN: Deadline is September 16, 2020 at midnight ET.  

HOW: The reference guides on this page have information you should consider including in your comments to CMS. The official guidelines on how to submit comments to CMS can be found in these guides.

If you are not a person living with cluster headache or a caregiver, but you wish to show your support, you may opt to sign on to this letter from the migraine and headache community. A personal comment is preferred, but this is also an option. 

Note: All comments submitted to CMS will be posted publicly on the CMS website. Only share information you are comfortable with being posted online. 

Looking for Assistance? During the Clusterbusters virtual conference (Sept 10-13), there will be a workshop to help patients draft their responses to CMS. Register today for the 15th Annual Clusterbusters Conference.

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

Sign on Letter for Supporters

Copy of letter

(Those who have not submitted their own comment)

CMS Website Links:



Submitted Letters:

AHDA’s Letter of Response

Sample Patient Comment