AACIPM Issues Recommendations on Comprehensive Pain Management Under Medicare

On September 6, 2022, AACIPM submitted a set of eight recommendations related to comprehensive pain management services to the Centers for Medicare & Medicaid Services (CMS) related to the proposed 2023 Physician Fee Schedule.

Issued in response to CMS’ newly proposed codes for comprehensive pain management (CPM) services, AACIPM, along with signatories representing patient organizations, large scale health systems, employer purchasers of healthcare, private insurers, pain management clinicians and educators, and other experts in the field of comprehensive and integrative pain management, offered the comments to CMS in the spirit of collaboration and partnership, aiming to help the agency achieve its goals of: (1) encouraging the adoption of high-quality integrative pain care while minimizing reliance on higher risk, low value care that is often more costly, (2) collecting accurate data on the number of people requiring treatment for chronic pain and the types of services they require, and (3) promoting health equity.

AACIPM is grateful to CMS for its recognition that adequate treatment of pain is a significant public health challenge and for the significant effort that has been invested in developing the proposed CPM codes (GYYY1 and GYYY2). The establishment of these CPM codes is an important step forward in chronic care management, and we are supportive of their implementation. However, along with our stakeholders, we have identified a number of potential negative unintended consequences that may occur should the codes be finalized as initially proposed, and have thus developed a number of solutions that we believe will enable the CPM codes to be best implemented and utilized.

Regarding the proposed CPM codes, GYYY1 and GYYY2, AACIPM recommends that CMS:

1. Clarify GYYY1 so that it is clear that clinicians are not responsible for providing every listed service, allowing for flexibility in individual treatment plans based on the patient’s needs and the geographically available services. (This could be done by adding “as appropriate” after all optional clauses, such as medication management, coordination with community-based care, and coordination with behavioral health treatment).
2. Clarify and/or redraft GYYY1 so it is clear that only the initial CPM visit is required to be in-person, and that follow-up CPM visits may be delivered in-person or remotely, whether or not they occur within the same month.
3. Add equivalent codes to GYYY1 and GYYY2 to the Telehealth Services list.
4. Allow providers to bill for GYYY1 (and GYYY2, as appropriate) on the same day that a patient is being seen for a general visit or for another illness or condition.
5. Crosswalk the valuation of GYYY1 and GYYY2 to 99214 (rather than 99424 and 99425) and consider adding a modifier that would compensate providers for the additional labor involved in providing CPM.
6. Replace “administration of a validated pain rating scale or tool” with “documentation of pain based on subjective and objective pain measures, including function and quality of life.”
7. Establish a Stakeholder Work Group, or issue an RFI, to further investigate subjective and objective pain measurement tools.
8. Remove any mention of “bundles” or “bundling” from the proposed CPM codes to eliminate confusion with traditional bundles that are based on outcome measures.

You can read the full letter to CMS here, along with all of the supporting rationale for each recommendation and the full list of signatories.