Dear Fellow Physician/Provider:
Please take a moment to read the content below because you have a window of time to potentially impact how you are reimbursed for patient care:
At the end of this email is a cut and paste letter that can be submitted as a comment to CMS – please read below.
Draft: https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-1003…
Summary: https://www.cms.gov/Medicare/Quality-Initiatives-P…
Participation in the Prescription Drug Monitoring Program (PDMP) is a specific activity under the Clinical Practice Improvement Activities (CPIA) category that providers will receive credit for which will count towards their total Merit-based Incentive Payment System (MIPS) score and subsequent adjustments in CMS payments through MIPS. While there are two categories of CPIA activities as a means of receiving enhanced quality-related payments, medium and high, currently under the Patient Safety and Practice Assessment Section of the CPIA activities, engaging in the PDMP is only weighted as a “medium” CPIA activity.
By upgrading the priority weighting of PDMPs in relation to other CPIAs, engaging in PDMPs would count more significantly towards the MIPS score and incentives and would encourage practitioners to prioritize engaging in PDMP activities. If PDMP participation is weighted more heavily in MIPS scoring, clinicians will adopt PDMP utilization more rapidly due to the financial incentives related to MIPS scoring.
This is open to public comment now until June 27, 2016. I am submitting a comment that strongly advocates reimbursing physicians more highly for this. Please copy and paste the comment below (also attached) to indicate your support for reimbursing physicians for participating in the prescription drug monitoring program.
Submit your comment to:
https://www.regulations.gov/#!docketBrowser;rpp=25;po=0;dct=PS;D=CMS-2016-0060
Please include your title, organization, city and zip code in the comments box, because the Department of Health and Human Services requests this information from all those who comment.
Thank you for your time and attention in this matter.
Sincerely,
Ezekiel Fink, MD
Director of Inpatient Pain, Houston Methodist Hospital
Assistant Clinical Professor, David Geffen School of Medicine/UCLA Department of Neurology
Triple Board Certified in Neurology, Pain Medicine, and Brain Injury Medicine
CUT AND PASTE THE FOLLOWING:
RE: Centers for Medicare & Medicaid Services
42 CFR Parts 414 and 495
[CMS-5517-P]
RIN 0938-AS69
Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative
Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for
Physician-Focused Payment Models
We have three comments that relate to the call for feedback related to the weight of CPIAs on pg. 334: “We seek comment on which activities should receive a high weight as opposed to a medium weight”.
(1) We support the “high” priority weight of the CPIA activity: “consultation of PDMP prior to the issuance of a Controlled Substance Schedule II (CSII) opioid prescription that lasts for longer than 3 days” (pg. 957).
(2) We encourage CMS to expand “high” priority weighting (listed above) to other schedule II prescriptions including benzodiazepines and stimulants.
(3) We encourage CMS to upgrade the weight of PDMP utilization from “medium” to “high” priority (pg. 957): “Annual registration by eligible clinician or group in the prescription drug monitoring program of the state where they practice. Activities that simply involve registration are not sufficient. MIPS eligible clinicians and groups must participate for a minimum of 6 months. (Medium)”.
By upgrading the priority weighting of PDMPs in relation to other CPIAs, engaging in PDMPs would count more significantly towards the MIPS score and incentives and would encourage practitioners to prioritize engaging in PDMP activities. If PDMP participation is weighted more heavily in MIPS scoring, clinicians will adopt PDMP utilization more rapidly due to the financial incentives related to MIPS scoring.
Additionally, there appears to be inconsistent language relating to the CPIA weighting of PDMPs.
On the MACRA NPRM list of CPIAs on pg. 957, it lists PDMP activities as “medium” (listed in #3 above). However, in the section describing the criteria which is used to determine the level of financial incentives provided through the MIPS program (pg. 166), PDMP is listed as a “high” priority CPIA:
“Programs that require performance of multiple activities such as participation in the Transforming Clinical Practice Initiative, seeing new and follow-up Medicaid patients in a timely manner in the provider’s State Medicaid Program, or an activity identified as CMS-5517-P TLP 4/25/16 167 a public health priority (such as emphasis on anticoagulation management or utilization of prescription drug monitoring programs) were weighted as high. The statute references patient-centered medical homes as achieving the highest score for the MIPS program. MIPS eligible clinicians or groups may use that to guide them in the criteria or factors that should be taken into consideration to determine whether to weight an activity medium or high on comments for this proposal. We request comments on this proposal, including criteria or factors we should take into consideration to determine whether to weight an activity medium or high.”
Again on pg. 334 PDMP is referenced as a “high” priority CPIA:
“Additionally, activities that require performance of multiple actions, such as participation in the Transforming Clinical Practice Initiative, participation in a MIPS eligible clinician’s state Medicaid program, or an activity identified as a public health priority (such as emphasis on anticoagulation management or utilization of prescription drug monitoring programs) are justifiably weighted as high. We seek comment on which activities should receive a high weight as opposed to a medium weight.”
Since the CPIA program is a significant factor in determining the MIPS score and incentive payments to clinicians, we strongly request that CMS deem PDMP activities as a “high” weight consistently throughout the listing of CPIA weights. This will ensure that PDMP related MIPS scoring will be commensurate with the relative importance of PDMP as a CPIA activity, resulting in rapid adoption and utilization of the PDMP. Furthermore, the “high” priority weight of consultation of PDMP prior to the issuance of Controlled Substance Schedule II (CSII) prescriptions will aid in addressing the current opioid epidemic and will incentivize physicians to prioritize this form of PDMP utilization.
I also want to advocate for “high” priority weight of consultation of PDMP for all controlled substances not restricted to opioids alone. This will ensure that other controlled substances with the potential for abuse (such as benzodiazepines) that are listed in the PDMP will also be routinely addressed.
Thank you,
YOUR NAME