The result of this effort was shared agreement across multi-stakeholder leaders representing payers, providers, patients

In response to a Centers for Medicare & Medicaid Services (CMS) proposed rule regarding changes to the 2022 Medicare Physician Fee Schedule, AACIPM has submitted a letter to CMS outlining the healthcare settings and practitioners that furnish non-opioid pain management, the resources involved in treating chronic pain, and how CMS might design new codes that will better enable health providers to classify and treat pain. The letter, submitted as a part of CMS’ public comment period, aimed to highlight the many diverse practitioners and services that may make up a comprehensive integrative pain management treatment plan, and further, to highlight the issues that these providers face when attempting to bill CMS for the pain care services which they provide.

To address the problems that providers of pain management are facing when attempting to bill CMS, AACIPM, along with 26 individual signers and 8 organizations, issued the following five recommendations:


  1. AACIPM supports the creation of standalone pain codes, both time-based and value-based, that will better describe the services provided by highly-skilled pain care providers, including certain Non-Qualified Health Professionals. The development of such codes will also aid CMS in reimbursing these clinicians for their services. While we acknowledge the need for an appropriate level of care coordination for pain management services, we encourage CMS to ensure that clinicians are able to provide services “at the top of their license or certification” by eliminating unnecessary direct supervision requirements and providing reimbursement for the full range of evidence-based, guideline concordant services that they provide.
  2. AACIPM urges CMS to establish a multi-stakeholder working group to determine operational details and resource allocation of establishing payment for evidence-based pain management services, including which Non-Qualified Health Professionals should be eligible for reimbursement of pain management services without direct supervision.
  3. AACIPM urges CMS to exercise its full regulatory authority to designate appropriate state licensed pain management providers—as well as providers authorized to provide pain management under Medicare Part C—with provider status under Medicare Part B.
  4. AACIPM respectfully requests that CMS establish a pilot program for bundled and/or case rate comprehensive integrative pain management care compared to historical controls or current usual care controls, enabling the agency to determine the cost-effectiveness of treating pain using innovative payment methodologies.
  5. AACIPM respectfully requests that CMS integrate the new ICD-11 pain codes into CMS coding and payment systems as quickly as possible.

Related Article:

AACIPM Issues Recommendations on Comprehensive Pain Management Under Medicare
(Sept. 2022)

Related Article:

CMS Takes Action on AACIPM Recommendations Regarding Bundled Payments for Integrative Pain Management (July 2022)