Opioid Treatment Program (OTP): CY 2022 Methadone Payment Exception (CMS-1751-IFC)
2021-12-10 2021-12-15 2021-12-01 2022-01-04 2021-12-10 2021-12-15 2021-12-10 2021-11-29
CMS-2021-0167-0008 CMS-2021-0167-0009 CMS-2021-0167-0004 CMS-2021-0167-0012 CMS-2021-0167-0007 CMS-2021-0167-0010 CMS-2021-0167-0006 CMS-2021-0167-0003
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It would be irresponsible of CMS to reduce OTP (Opioid Treatment Program) reimbursement for methadone while the current PHE is exacerbating opioid use disorders in the Medicare population. We need more, not less, support for medication-assisted treatment providers, and reducing reimbursement rates for methadone would likely make this drug less available to those who need it most. This is critical to avoid further opioid-related deaths. Given the growing crisis, CMS should seek options to make methadone treatment more widely available by authorizing it to be dispensed in a pharmacy setting and/or increasing reimbursement rates to existing treatment providers. Given the abundance of pharmacies in most communities, this would capitalize on the existing pharmacy infrastructure and enable Medicare beneficiaries who are otherwise limited in treatment options to pursue medication-assisted treatment such as methadone.  With the nation in the grips of both the COVID-19 pandemic and the enduring opioid epidemic, it is critical to ensure continued access to recovery from opioid use disorder (OUD) for Medicare beneficiaries. The proposed rule to freeze payment to Opioid Treatment Programs (OTPs) for methadone in calendar year 2022 at the current calendar year 2021 rate should be implemented to protect access to methadone treatment. Over 1.2 million individuals over the age of 65 struggled with substance use disorder (SUD) in 2019.  However, only 23.6 percent received treatment.  The number of older adults seeking treatment for OUD specifically increased nearly 54 percent between 2013-2015, as the opioid epidemic began to accelerate, affecting individuals regardless of age, race, income, and other demographics.  More than 200,000 Medicare beneficiaries nationwide have died due to opioid overdoses since 2015.   Additionally, SUD is associated with many negative outcomes including health complications, accidents due to impairment, and decreased productivity. Individuals ages 65 and over are especially vulnerable during the pandemic. According to the National Institute on Drug Abuse (NIDA), the effects of many substances, including opioids, such as impaired judgement or coordination, can lead to falls and motor vehicle accidents, which pose a much greater risk for older adults. Additionally, NIDA research shows that older adults are more likely to suffer from mood disorders, heart conditions, and cognitive disorders, all of which can worsen due to SUD, increasing negative health outcomes.  Though rates of opioid use and overdoses were increasing as the pandemic began, they have surged to new highs, with a 28.5 percent increase over the first 12 months of the pandemic.  Older adults are more likely to be isolated due to the pandemic and more likely to have access to prescription opioids. Overdoses among Medicare beneficiaries rose by roughly 200 per month during the second half of 2020, during the heights of the pandemic.   With the rates of overdose and OUD rising among Medicare beneficiaries, it is necessary to ensure continued access to OUD treatment. Medication-assisted treatment (MAT), which combines medications such as methadone and Suboxone with individual and group therapy, has proven to be the most effective treatment for OUD, and therefore it is critical to protect and expand access to MAT, especially as the pandemic continues.  Many individuals struggle to find openings in existing MAT programs. Others are in communities without access to MAT at all.  A 2019 University of Michigan study identified the biggest barriers to MAT treatment, according to providers, are state regulations and reimbursement rates.  Additionally, as the opioid epidemic has spread, public support for prevention and treatment of OUD has significantly increase, decreasing stigma, a significant barrier to treatment. The addition of methadone treatment as a Medicare Part B benefit in January 2020 expanded access to MAT to a large portion of older adults struggling to find recovery.  However, a sharp and dramatic decrease in the reimbursement rate for methadone could upend that progress. As stated above, providers have identified reimbursement rates and costs as one of the top barriers to MAT. Slashing the reimbursement rate for methadone, especially with so little data available, could lead to financial impacts for clinics providing methadone treatment, significant cost sharing for Medicare beneficiaries, and other barriers to treatment at a time when the pandemic is fanning the flames of the opioid epidemic. It is possible that freezing the rate at the current level will still result in some of these negative outcomes, as supply chain and logistics issues have driven up prices across the country and the globe. It is possible an increase is necessary. However, freezing the rate at the current level is a prudent solution for the moment. As stated in the proposed rule, a year will allow CMS additional time to study methadone use among Medicare beneficiaries, the prevalence of the two available methadone formulations, as well as potential alternative reimbursement formulas, given the unique nature of methadone. Though it is concerning, given widespread inflation, that the rate will remain static in calendar year 2022, CMS rationale for this proposed rule is sound, and allows for additional time to study methadone treatment in general, a new benefit for Medicare. The proposed rule prevents a sharp decrease in the reimbursement rate, which could have injected chaos into the already fragile MAT infrastructure. Upon implementation of the proposed rule, it is critical that CMS dedicate significant time and resources to studying methadone treatment and reimbursement, as well as additional MAT options, particularly as the pandemic and opioid epidemic endure.  Please continue to keep current payment rates. We struggle as it is to have enough providers to provide these services. Decreasing would greatly impact them. PCMA appreciates the opportunity to comment on the U.S. Centers for Medicare  Medicaid Services interim final rule related to Opioid Treatment Programs: CY 2022 Methadone Payment Exception (interim final rule).   This is a very important issue and the action that is being taken is a step in the right direction. Addiction is a ruthless disease and it can happen to anyone. Thank you for the opportunity to comment.  I am a disabled physician.  Please maintain or increase rates for reimbursement for treatment of pain and addiction such as with methadone.  Lack of access is driving the overdose deaths.  Lack of reimbursement and difficulty of practice is driving providers out.  Eliminating the annual process to review methadone coverage treatment for CY 2022 to avoid implementing a possible decrease in the payment amounts for methadone for Medicare beneficiaries has been welcoming news for many who are indirectly or directly affected. I fully support maintaining the CY 2021 payment rate for methadone to treat opioid use disorders into CY 2022. While many people might agree simply because it feels like the right thing to do, data across states indicate that this measure is critical for the fight against opioid overdose during the Coronavirus Disease 2019 (COVID-19)  pandemic. The Centers for Disease Control and Prevention reported an increase in the use of opioids as the COVID-19 brought about lockdowns and quarantines. Prior to COVID- 19 opioid overdose cases consistently increased, but between May 2019 to May 2020, the United States saw 81,000 overdose deaths, the largest ever recorded. While some data suggest that steps taken have improved prescription opioid misuse and fatalities, there have been increases with synthetic opioids such as Fentanyl, which is 50 to 100 times more potent than morphine. Prescription opioid misuse among medicare beneficiaries tends to come from chronic pain as they age.The report states that nearly one million adults age 65 and older live with Substance Use Disorders (SUD). This number is almost certain to have increased over the years, following the increasing trend and the effects of the pandemic. It emphasizes the need to increase OTPs and expand the services offered across all states. Opioid use among older adults can result in excessive sedation, respiratory depression, impairment in vision, attention, coordination, and falls. Currently, falls are the leading cause of injury-related death among adults age 65 and older.Decreasing the payment rate to Opioid treatment programs from $37.38  to $17.64 would have grave consequences, limiting access to  SAMSHA certified and Medicare/Medicaid enrolled  Opioid Treatment Programs (OTP). Many programs may choose not to participate due to inadequate funding. These OTPs also provide psychosocial services. Most of these services have been transitioned to Telemedicine, thereby improving access. Data studying a clinicians perspective on methadone service delivery indicate that 85 % of OTPs offered Telemedicine for medication management, psychosocial services, or both. These services might not be provided if payment rates are reduced.Another factor to consider is that a decreased rate may hinder the enthusiasm and motivation of employees at OTPs. Compensation and benefits are directly related to employee motivation. Low employee morale can adversely affect attracting and retaining the best employees and negatively affect productivity.While this interim final rule (IFC) freezes the payment to OTPs for methadone in CY 2022 at the CY 2021 rate, the annual update to the non-drug component of HCPCS G2067 for CY 2022 as required under 410.67(d)(4)(iii) will be applied. It is worth noting that the effects of the pandemic on opioid use disorders will be long-lasting, possibly several years. Much of the data required for evidence-based decision-making has been undermined by poor data collection, tracking, and COVID-19 restrictions. Opioid overdose is a public health crisis requiring increasing public awareness about prescription misuse, overdose, and making safe choices while providing both drug treatments and non-drug therapy.According to the  Centers for Disease Control and Prevention, the U.S. economic cost of opioid use disorder was 471 billion and fatal opioid overdose $550 billion during 2017, a total cost of $1,021 billion The combined costs varied from $985 million in Wyoming to $1,204 in Hawaii. Federal and state public health agencies can use these data to help guide research, prevention, and resource allocation decisions.  Washington State supports the proposed retention of the current Medicare payment rates for Methadone used for Opioid Use Disorder in SAMSHA certified and Medicare enrolled Opioid Treatment Providers (OTP).