Submissions to Government Agencies

As the research base for acupuncture has grown and yet much misinformation regarding acupuncture persists, the Acupuncture Now Foundation has made several submissions to policymakers in different countries and aided several groups in their submissions. Below are descriptions of our submissions to policy making agencies that highlight the research evidence and put that evidence into perspective.

Center for Medicare and Medicaid Services

Acupuncture is "Reasonable and Necessary" for Peripheral Neuropathy. This is the formal request the ANF sent to the U.S. Center for Medicare and Medicaid Services requesting they start a National Coverage Determination (NCD) process to consider approving acupuncture for peripheral neuropathy. We included 72 full studies and wrote a detailed description of the most relevant studies. They eventually told us they wanted to see additional studies before they would consider opening an NCD and we continue to work on this.

California COVID-19 Community Vaccine Advisory Committee

Comments to the California COVID-19 Community Vaccine Advisory Committee on January 4, 2021

U.S. Department of Health and Human Services

Comments to the U.S. Department of Health and Human Services April 2019

Recommended, not recommended, strongly recommended

Below are comments the ANF and ANF affiliates sent to the U.S. Centers for Medicare/Medicaid Services (CMS) on chronic low back pain as part of their National Coverage Determination process in February 2019. The CMS then proposed that they wanted a study on Medicare age low back patients before they would approve acupuncture for low back pain. They solicited feedback on that proposed decision. The last in this list is our final comments asking CMS to accept the earlier findings and not wait for more studies to approve acupuncture for chronic low back pain. They finally did approve the use of acupuncture for chronic low back pain - the first time acupuncture was approved by Medicare for any condition. Unfortunately, Licensed Acupuncturists are still not approved for Medicare payments and so most Licensed Acupuncturists can't treat Medicare low back patients unless they work with a Medical Doctor that can bill Medicare.

Noninvasive, Nonpharmacological Treatment for Chronic Pain: A Systematic Review

Comments from the Acupuncture Now Foundation to the AHRQ draft report December 26, 2017

AHRQ draft report: Noninvasive, Nonpharmacological Treatment for Chronic Pain: A Systematic Review (PDF)

Comments from the Acupuncture Now Foundation to the AHRQ draft report December 26, 2017

Acupuncture in Pain Management: Strengths and Weaknesses of a Promising Non-Pharmacologic Therapy in the Age of the Opioid Epidemic. FDA Position Paper

Proposed 2016 Guideline for Prescribing Opioids for Chronic Pain

Joint Acupuncture Opioid Task Force CDC Submission 2016

Medical Treatment Utilization Schedule

Full Letter to the Department of Workers' Compensation (PDF)

ANF Response to NICE Draft Guideline

The National Institute for Health and Care Excellence (NICE) is an independent organization, established by the British government in 1999. NICE reviews evidence and decides which treatments are to be made available (and paid for) by the National Health Service (NHS) in England and Wales but their guidance is considered by healthcare policy makers globally.

When NICE released their draft guidelines on treatment for low back pain and sciatica, they recommended a reversal of their 2009 decision to recommend acupuncture as an effective treatment for low back pain. They proposed that acupuncture should not be used for low back/sciatica because they believe the research does not definitively support that acupuncture works beyond "sham." The ANF emphatically disagrees with this finding and helped lead an effort to pour over the NICE research methodology. When we did so, we found several outright reporting errors as well as illogical and even unethical thinking behind their rational for their findings. The following submission to NICE as a joint effort between the ANF and England’s Northern College of Acupuncture both of whom registered with NICE as stakeholder organizations. We await word from NICE if they will change their policy due to the substantial missteps in their procedures.

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