ASA Urges Changes to Medicare Part D Opioid Prescriptions Program

On March 5, the American Society of Anesthesiologists (ASA) submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on certain changes to Medicare for CY 2019, including the Part D program and concerns about proposed changes regarding the overutilization monitoring system (OMS). The OMS, which helps CMS ensure that sponsors have established reasonable and appropriate drug utilization management programs, is designed to assist in preventing overutilization of certain prescribed medications. With the growing concern around opioid abuse, misuse and addiction, CMS is making further changes to its opioid overutilization policy.

In its letter, ASA expressed concern with the proposal around cumulative morphine milligram equivalent daily dose (MME) safety edits for high, chronic opioid users. Specifically, the Advance Notice cites the Centers for Disease Control and Prevention (CDC) Guideline for Prescribing Opioids for Chronic Pain (CDC Guideline) as reason for requiring that all sponsors implement a hard edit, triggered when a beneficiary’s cumulative daily MME reaches or exceeds 90 mg. ASA finds this very problematic, as the CDC Guideline was not meant to address all patients on opioid therapy— rather, only patients in the primary care setting who are not under the care of specialists in pain medicine. These proposed changes may result in unintended consequences such as restrictions on beneficiaries living with severe, chronic pain who remain fully functional on stable doses of opioids for years. For this reason, ASA recommends that CMS create a specific exception for patients under the care of a pain specialist.

ASA also responded to a CMS proposal that would create a 7-days supply limit of initial fills of prescription opioids. ASA finds this proposal problematic, and instead, suggests CMS take into consideration patients who have just undergone surgery, where the appropriate opioid dose should be at the discretion of the physician, weighing the patient-specific factors in the relevant circumstance.

As leaders in pain medicine and patient safety, ASA will continue to work with federal agencies to develop effective and common-sense pain management strategies. ASA will continue to monitor the development of this policy in the final Announcement of Calendar Year 2019 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies, expected in the coming months.