MOA Action Alerts & Updates!
Maine CDC Publishes Modified Opioid/PMP Rule
Friday, March 31st, saw the Maine CDC publish its "final" version of the opioid prescribing and PMP use rule. You can read the entire rule here.
Here are some of the new changes:
- the definition of "opioid medication" includes all controlled substances containing opioids, not just Schedule II drugs.
- the term "administer" is now defined.
- a prescriber's duty to review the PMP check done by a delegate is defined.
- prescriptions must include notations of the prescriber's DEA number; whether the pain being treated is acute or chronic; a notation of "acute" when prescription is for "acute on chronic" pain; and as any exemption being claimed
- notation of ICD-10 codes is only necessary when claiming the palliative care exemption
- a new exemption has been created for situations where a patient proves intolerant of a prescribed opioid and must get another (Code H)
- the rule sets out the types of information the CDC is looking for when reviewing PMP information
All physicians who prescribe opioids should review the new rule as soon as possible.
Electronic Opioid Prescribing Waiver Applications Now Available from Maine CDC
Maine's new opioid law, PL 2015 c. 488, includes a requirement that all opioid prescriptions be done electronically. Of course, there will be circumstances where that is either impossible, extremely difficult or burdensome. The Maine CDC has now (as of April 3, 2017) issued a waiver application that is available online at http://www.maine.gov/dhhs/samhs/osa/data/pmp/E-Prescribing-Waiver-and-Policy_Individual.pdf .
This is what the CDC says about the waiver requirements:
- "Waivers may be granted based on documentation by a practitioner that his or her ability to issue an electronic prescription is unduly burdened by: technological limitations that are not reasonably within the control of the practitioner; or other exceptional circumstances demonstrated by the practitioner. Detailed evidence of, technological limitations and other exceptional circumstances must be provided, including all steps that are being taken, in the interim, to meet this mandate. A waiver may be granted for a period determined appropriate by the department not to exceed twelve (12) months, although the Department may renew the waiver upon a new demonstration that the practitioner’s ability to issue an electronic prescription is unduly burdened."
CMS Releases New Resources to Help Clinicians Successfully Participate in QPP
CMS has recently revamped the look of the QPP website and also posted new resources to help clinicians successfully participate in the first year of the QPP. The following new resources have been posted to the website:
MIPS quick start guide: Outlines the steps clinicians participating in the Merit-based Incentive Payment System (MIPS) need to take between now and March 2018 to prepare for and participate in MIPS, including checking participation status, choosing to participate as an individual or as part of a group, deciding how to submit data, and selecting measures and activities.
Medicare Shared Savings Program and QPP fact sheet: Explains how the Shared Savings Program and the QPP align reporting requirements for participating ACOs and MIPS clinicians, and how certain tracks in Shared Savings Program ACOs meet Advanced Alternative Payment Model (APM) criteria under the QPP.
MIPS APM fact sheet: Provides an overview of a specific type of APM, called a "MIPS APM," and the special APM scoring standard used for those in MIPS APMs.
CMS releases "CAHPS for MIPS" conditionally approved survey vendor list
Physicians who plan on reporting the CAHPS for MIPS measure as one of their quality measures to satisfy MIPS requirements in 2017 must use a CMS-approved CAHPS for MIPS survey vendor. As conditionally approved survey vendors, these organizations have demonstrated they have the facilities, project experience and staff expertise required to conduct the 2017 survey administration with appropriate rigor, given the demands of the survey procedures and timeline.
Final approval of these organizations is dependent on satisfactory completion of CMS training and submission of a Quality Assurance Plan. A final list of the CAHPS for MIPS survey vendors approved by CMS to administer the 2017 survey will be made publicly available this summer.
Keep in mind, physicians who are reporting the CAHPS for MIPS measure must register and inform CMS by June 30, 2017.
An Update on Opioid Health Homes
MaineCare's new Opioid Health Home (OHH) program has begun accepting applications from organizations wishing to be considered for the designation. Amy MacMillan (previously Dix) at MaineCare can be reached at Amy.MacMillan@maine.gov. Currently, Section 93 Emergency Rule is in effect at https://www1.maine.gov/sos/cec/rules/10/ch101.htm/ Comments are being taken until May 18th. We encourage groups to submit comments at http://www.maine.gov/dhhs/oms/rules/proposed.shtml#anchor741339.
In addition, the Maine Office of Substance Abuse and Mental Health Services has a program to cover uninsured for MAT treatment. The coverage will be provided through contracts to agencies that are approved as providers for Opioid Health Homes. As applications are received and approved, the Office of Substance Abuse and Mental Health Services will reach out to OHHs to encumber funds. Mike Parks, Associate Director, DHHS, Office of Substance Abuse and Mental Health Services, can be reached at firstname.lastname@example.org for questions about this part of the program.