AACIPM acts as a connector, even between staff at Health & Human Services (HHS) agencies, who tell us they appreciate being kept abreast of what each specific agency is doing as it relates to pain care. This section is intended to help synthesize HHS highlights, and we welcome your feedback for future updates.
CDC Opioid Workgroup: Proposed Overhaul of Opioid Guideline Doesn’t Go Far Enough
On July 16, 2021, the CDC National Center for Injury Prevention and Control (NCIPC) presented their Updated Draft Opioid Prescribing Guideline. While the draft has not been released to the public yet, the Opioid Workgroup of the Board of Scientific Counselors of the NCIPC has released their observations, making it clear that they were unhappy with the proposed updates.
Workgroup members are concerned, in part, that:
- Much of the supporting text of the guideline was not balanced, was missing key studies, and focused heavily on the risks of opioids, while less attention was focused on the potential benefits of opioids, or the risk of not taking opioids or undertreating pain.
- The guideline paid too little attention and had minimal discussion about racial/ethnic disparities and inequities in how pain is perceived, valued, and managed, and the potential implications of these disparities on implementation of the guideline.
- A sense of exceptionalism ran throughout the guideline, with some pain conditions being named within the guidelines and treated as “real” or “worthy” of treatment, while others were not.
At the essence of the workgroup’s concerns is that none of the provisions from the 2016 guideline that were so often misapplied in the past five years have been sufficiently changed to prevent future harm. To show how little the guideline has been changed, U.S. Pain Foundation released a side-by-side comparison of the 12 recommendations that appear in the 2016 guideline and the 2021 draft. Advocacy groups have also voiced their concerns that the draft does not go far enough in overhauling the guidelines, with the AMA urging the CDC to remove arbitrary thresholds, restore balance and support comprehensive, compassionate care as it revises the guideline.
In response to the Workgroup’s observations and concerns, CDC accepted public comments for just one week after their meeting based upon those observations. Those comments will be included as a part of the July 16thmeeting’s minutes.
HHS Extends COVID-19 Public Health Emergency,Telehealth Waivers
The federal government has extended the COVID-19 Public Health Emergency until at least October 20, 2021, which means that all telehealth and other waivers that have been implemented during the Public Health Emergency will remain in effect for now.
For additional information on Public Health Emergency waivers related to telehealth, HIPAA flexibility, billing and reimbursement, and more, check out HHS’ page on Telehealth: Delivering Care Safely During COVID-19.
PCORI Accepting Public Comments on National Priorities for Health
The Patient-Centered Outcomes Research Institute (PCORI) has released their Proposed National Priorities for Health, and is accepting public comments until August 27, 2021.
The five proposed National Priorities for Health, below, are wide-ranging areas that are intended to reflect what is most important to patients, stakeholders, and the broader healthcare community. Those priorities will then serve as a framework to guide PCORI’s funding decisions and related initiatives.
Proposed Priorities Include:
- Increase Evidence for Existing Interventions and Emerging Innovations in Health
- Enhance Infrastructure to Accelerate Patient-Centered Outcomes Research
- Advance the Science of Dissemination, Implementation, and Health Communication
- Achieve Health Equity
- Accelerate Progress Toward an Integrated Learning Health System
If you’d like to help PCORI shape the future of patient-centered health research, we encourag hrefe you to respond to their call for public comment. There are four prompts for each proposed priority, or you can provide your comments on the full set of proposed priorities. In addition, you can submit your comments as a PDF document or send them in via email to NPPC@pcori.org.
CMS Proposes 2022 Medicare Physician Fee Schedule, Accepting Comments
On July 13th, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule outlining changes to the Medicare Physician Fee Schedule (PFS) and other Medicare Part B payments for Calendar Year (CY) 2022. The proposed rule contains many pain-specific provisions and presents an exciting opportunity for advocates to provide information that could substantially impact CMS payment structure in regard to pain management.
CMS is specifically soliciting comment on a number of pain-related issues, including, but not limited to:
- Whether CMS should create separate coding and payment for medically necessary activities involved with chronic pain management and achieving safe and effective dose reduction of opioid medications when appropriate, or whether the resources involved in furnishing these services are appropriately recognized in current coding and payment.
- Which healthcare settings and stages in treatment transitions from opioid dependence are occurring, as well as what types of practitioners furnish these services.
- Whether the specific activities listed by CMS within the proposed rule (diagnosis, assessment and monitoring, medication management, patient education and self-management, crisis care, specialty care coordination, etc.) are appropriate, and whether there are other activities that should be included.
- How CMS could define and value separate coding or an E/M add-on code.
- Whether any components of the service could be provided “incident to” the services of the billing physician who is managing the beneficiary’s overall care similar to the structure of the Behavioral Health Integration (BHI) codes, which can include BHI services that are not delivered personally by the billing practitioner and delivered by other members of the care team (except the beneficiary), under the direction of the billing practitioner on an incident to basis.
Comments to the proposed rule change will be accepted through September 13, 2021. The AACIPM team is currently exploring if it will facilitate another group sign-on comment, such as the letter submitted by AACIPM in response to AHRQ’s request for public comment on its systematic review for integrated pain management. If you are interested in being a part of this, contact Amy Goldstein.
Proposed 2022 Funding Bill Would Significantly Increase Pain Funding
The House Appropriations Committee recently released the draft fiscal year 2022 Labor, Health and Human Services, Education, and Related Agencies funding bill. The bill provides a total of $49 billion for NIH, an increase of $6.5 billion above the FY 2021 enacted level. If passed as currently drafted, the legislation will increase funding for opioids, stimulants, and pain management by $627 million, as well as increase funding for health disparities research by $330 million. The bill also provides for major health infrastructure funding, including $1 billion in a new, flexible funding stream for public health infrastructure and capacity nationwide and $106 million for public health workforce initiatives.