ASRA Responds to CMS Revisions to Payment Policies and Other Medicare-Related RequirementsSep 24, 2019
As part of its ongoing commitment to providing regulatory advocacy to our members and their patients, ASRA recently submitted its comments to CMS-1715-P and other revisions and requirements recently proposed by the Centers for Medicare and Medicaid Services (CMS).
Here is a summary of the comments:
- CMS proposes to add the face-to-face portions of three new G-codes for overall treatment of opioid use disorder (OUD) to the list of Medicare telehealth services for calendar year (CY) 2020. With some concerns about bundled payments for substance use disorder treatment services (see item 3), ASRA supports this proposal.
- CMS proposes to cover OUD treatment services furnished by opioid treatment programs, consistent with the SUPPORT Act. ASRA supports this with the added recommendation that CMS facilitate increased access to multimodal pain management therapies through its Medicare payment and other policies as part of its overall strategy.
- ASRA firmly believes that care and treatment for substance use disorders, including OUD, is extremely important. However, as noted in item 1, rather than creating a bundled episode of care, ASRA encourages use of codes that currently exist to cover this work – although they may not be widely used or known by fee-for-service providers and Medicare Advantage plans unfortunately do not always accept them.
- ASRA strongly supports CMS’s proposal to allow billing practitioners to review and verify, rather than re-document, information included in the medical record by physicians, residents, nurses, students, or other members of the medical team.
- ASRA recommends that CMS work with the medical community to place clearer guidelines around the use of principal care management codes, particularly as they relate to CMS’ proposals for evaluation and management (E/M) visits, in order to protect against excess utilization and inappropriate billing.
- In the valuation of specific services, ASRA urges CMS to accept the values recommended by the American Medical Association Relative Value Scale Update Committee and medical specialty societies.
- ASRA supports CMS finalizing most of its E/M policies as proposed. However, ASRA recommends that CMS put in place clearer guidelines around the use of CMS’s simplified add-on code, GPC1X, in order to protect against excess utilization and ensure appropriate access to pain management services.
- ASRA appreciates CMS's efforts to address some of the challenges clinicians face with the current merit-based incentive payment system (MIPS) program. However, the MIPS Value Pathways framework, as described, does not address some of the fundamental issues associated with performance measurement under MIPS and may rely on mandatory assignment, which ASRA would oppose.
- ASRA supports and encourages CMS to finalize the addition of the “Multimodal Pain Management” quality measure.
- ASRA appreciates and supports CMS’s proposals to update the Total Per Capita Costs measure to ensure it focuses on primary care. However, ASRA continues to have concerns about the use of this and other administrative claims-based cost measures in a clinician-level quality improvement program.
- ASRA strongly encourages CMS to ensure that all of its OUD therapy policies, to include the establishment of quality and other measures, are premised on the key domains of pain management known as the four A’s (analgesia, activities of daily living, adverse side effects, and aberrant drug-taking behaviors). ASRA strongly supports and urges CMS to make the Query of Prescription Drug Monitoring Program measure eligible for 5 bonus points for the Electronic Prescribing objective in CY 2020 but is concerned with making it optional, as this could diminish reporting, which is essential given the current opioid epidemic. In addition, ASRA supports potential new measures for OUD prevention and treatment that could be included in future years of the Promoting Interoperability (PI) category, with an emphasis on those that evidence-based, non-opioid pain management therapies and safe, evidence-base use of opioids when medically appropriate in treating patients with chronic and acute pain. Further, ASRA supports and urges CMS to finalize the three National Quality Forum-endorsed quality measures, stewarded by the Pharmacy Quality Alliance, that evaluate patients with prescriptions for opioids in combination with benzodiazepines, at high-dosage, or from multiple prescribes and pharmacies. Finally, we support the development of PI measures stemming from the CDC Quality Improvement Opioid Measures.
The full letter provides further details on ASRA's stance regarding this collection of proposals and can be read here.
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