AIPM Cautions CMS Against Misapplying CDC Guideline, Urges Coverage of Non-Opioids
Tuesday, March 6, 2018
Posted by: Katie Duensing, J.D.
In response to a request from the Centers for Medicare & Medicaid Services (CMS) for public comments related to CMS’s proposed payment policies for 2019, AIPM submitted comments presented in two parts: (1) Limitations on Opioids, and (2) Use of Non-Pharmacological or Non-Opioid Pain Management Interventions.
Limitations on Opioids
Under this proposed policy, payment would be denied for two types of prescriptions:
- Prescriptions for any beneficiary where cumulative opioid dose exceeds a calculated total dosage of 90 morphine milligram equivalents (MME) per day, subject to appeal.
- Prescriptions for durations of seven days or greater for “opioid naïve” patients, without exception or variation for any human circumstance including cancer or other diagnosis, receiving palliative or hospice care, or major geographic barriers.
We strongly opposed these two proposals on multiple grounds:
- The proposed policy does not align with the CDC Guideline for Prescribing Opioids for Chronic Pain.
- The proposed policy will accelerate non-patient-centered, nonconsensual opioid dose reductions.
- The proposal does not consider adverse impacts on pharmacies, providers, or patients, and it will very likely accelerate patient abandonment.
- The proposal does not include metrics to evaluate how it affects patient health or access to care.
- The proposal ignores important exceptions that have been preserved by state statutes.
Use of Non-Pharmacological or Non-Opioid Pain Management Interventions
Within CMS’s proposed policy, it is stated that, “CMS and measure developers are exploring additional measurement concepts for future work, such as functional status, and use of non-pharmacological or non-opioid pain management interventions…”
AIPM recently sent a letter to the U.S. Senate Committee on Finance related to these very issues, so we reiterated our suggestions related to CMS:
- Reimburse primary care providers and pain specialists for longer initial visits and frequent follow-up visits with chronic pain patients.
- Address additional financial barriers that prevent many Medicare and Medicaid beneficiaries from seeking non-pharmaceutical treatments for pain. Specifically, CMS should:
- Allow a greater number of physical and occupational therapy sessions annually, and should allow patients to access physical and occupational therapy without first acquiring a referral or prior authorization.
- Provide full coverage of chiropractic adjustments and osteopathic manipulations and other techniques and modalities and should allow a greater number of sessions annually.
- Provide full coverage for acupuncture, massage therapy, biofeedback, yoga and tai chi.
- Provide coverage of behavioral health services for the prevention, treatment, or management of physical health problems.
- Provide coverage of medical devices that are FDA-approved for the treatment of chronic pain.
- Fund long term (greater than 12 weeks) research studies evaluating the effectiveness of non-pharmaceutical treatments for chronic pain.
- Fund (through the Center for Medicare & Medicaid Innovation) Innovative Demonstration Projects using integrated, non-pharmacological treatments for chronic pain care.
Read AIPM’s full letter to CMS