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CMS Continues to Combat the Opioid Epidemic

Last month, we highlighted a few of the changes CMS proposes in Parts I and II of the Advance Notice and Draft Call Letter. Here, we take a look at CMS’s next steps to combat opioid misuse.

CMS says it best in its Fact Sheet:

Opioid pain medications are effective at treating pain in certain circumstances, but have serious risks such as addiction, abuse, misuse, overdose, and death CMS is deeply concerned about the magnitude of the opioid epidemic and its impact on our communities, and is committed to a comprehensive and multi-pronged strategy to combat this public health emergency.

CMS is implementing many new policies in 2019 that were announced in the CY 2019 Final Rules and CY 2019 Call Letter.  These new policies include increased oversight through the overutilization monitoring system (OMS), Part D drug management programs for high-risk users, improved safety alerts for concurrent use of opioids and benzodiazepines, and a 7-day supply limit for new opioid users.  CMS proposes to continue these policies in 2020, while evaluating the success and impact during 2019. 

CMS also proposes a number of new initiatives for 2020 to combat prescription opioid overuse:

  1. Pain Management and Complementary Treatments: CMS encourages MA plans to consider offering non-opioid pain management as supplemental benefits. Examples include peer support services, counseling services, chiropractic services, acupuncture, and therapeutic massage, among others.
  2. Improving Access to Opioid-Reversal Agents: CMS proposes strategies to improve access to naloxone such as lower beneficiary cost-sharing and promoting co-prescribing of naloxone when appropriate. CMS welcomes comments from stakeholders on the feasibility of these proposals.
  3. Star Ratings: CMS also proposes to advance opioid-related measures through the Star Ratings development process. The measures currently on the display page or under consideration include:
    • Use of Opioids at High Dosage and from Multiple Providers (current display measure)
    • Separate Use of Opioids at High Dosage and Use of Opioids from Multiple Providers measures (proposed display measure); and
    • Concurrent Use of Opioids and Benzodiazepines (proposed display measure).

CMS will accept comments on all proposals in Part I and Part II through Friday, March 1, 2019.  Comments can be submitted electronically at; enter the docket number “CMS-2018-0154” in the “Search” field, and follow the instructions for “submitting a comment.” 

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Bridgette advises health care providers, ACOs, health plans, PBMs, and laboratories on regulatory, fraud and abuse, and business planning matters, applying her experience in health system administration and ethics in health care to her health law practice.