CMSOn Jan. 5, the Center for Medicaid and Medicare Services (CMS) published a new, 30-page proposal for curbing opioid abuse: “Opioid Misuse Strategy 2016.” Among the more controversial suggestions are incentivizing pharmacists to report clinicians who appear to be overprescribing opioids and encouraging patients and providers to report on pharmacists who may be dispensing inappropriately.

CMS did not say when it planned to implement the strategy or if public hearings would be held.

The four proposed strategies are:

  1. Implement more effective person-centered and population-based strategies to reduce the risk of opioid use disorders, overdoses, inappropriate prescribing, and drug diversion;
  2. Expand naloxone use, distribution, and access, when clinically appropriate;
  3. Expand screening, diagnosis, and treatment of opioid use disorders, with an emphasis on increasing access to medication-assisted treatment; and
  4. Increase the use of evidence-based practices for acute and chronic pain management.

While U.S. Pain strongly supports efforts to reduce opioid misuse, it cautions that some strategies – like the call for added scrutiny and policing of opioid prescriptions amongst pharmacists and clinicians – may lead to the undertreatment of chronic pain.

“We are concerned that pitting pharmacists, physicians, and patients against one another will create a negative environment that is counterproductive to the collaboration and patient-provider relationship required for effective, high-quality health care,” said Cindy Steinberg, national director of policy and advocacy for U.S. Pain. “Because of the current backlash against opioids, many clinicians already are afraid to prescribe them—even when they are necessary and appropriate for a patient’s pain management. Threatening doctors with punitive measures even when prescribing appropriately is leading to unintentional and unnecessary patient suffering.”

The organization said it does support some of the other measures proposed in the document, including the increased availability of naloxone and expanded screening, diagnosis, and treatment for opioid-use disorders. While U.S. Pain also supports the call for an increased focus on alternative, non-pharmacological treatments, such as physical therapy, cognitive behavioral therapy, chiropractic and others as well as non-opioid pharmacological treatments, Steinberg says CMS has not been specific about what they will do to ensure that these alternative treatment modalities will be covered and payers that work in conjunction with CMS.

“The successful management of chronic pain requires an individualized combination of therapeutic modalities that work together to reduce a person’s pain to manageable levels,” says Steinberg. “We want health care providers to understand that the best outcomes result when they partner with their patients to find the right combination of treatments for that patient. For some patients, particularly those with severe pain, opioid analgesics in combination with other modalities such as physical therapy, occupational therapy, mind-body approaches, and many others may result in the best outcomes for those patients and they should be used. Repeated studies have shown that the overwhelming majority—greater than 90 percent of legitimate pain patients—do not become addicted to nor abuse their medication. We have to make sure that efforts to combat opioid abuse do not unfairly punish people living with pain who use them appropriately and benefit from their use.”

To read the full CMS document, click here.

CMS is accepting public comment on the strategy through March 3. To submit comment, email AdvanceNotice2018@cms.hhs.gov.