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This week, C-TAC submitted comments to CMS in response to a proposed rule regarding the Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Acute Care Hospital (LTCH) Prospective Payment System. The comments covered a variety of topics, including the following:
Hospital Inpatient Quality Reporting (IQR) Program
C-TAC supported the proposed exemption of those with cancer or receiving palliative care from proposed the Safe Use of Opioids measure, and appreciated CMS confirming that these populations should be exempted from any opioid measures or guidelines, based on the 2016 CDC Guidelines for Prescribing Opioids for Chronic Pain.
Proposed Removal of Pain Management Questions from PCHQR Program
C-TAC does not support removing the Pain Management questions from the PCHQR program, explaining that pain is a key reason for hospital admission and a prevalent symptom among those living with advanced illness. Instead of removing these questions, C-TAC recommends that CMS should aggressively pursue new measures that adequately capture a hospital’s performance on pain management and determine whether any such questions encourage opioid overuse.
Medical Condition and Comorbidity Data Elements
C-TAC approved of adding the proposed “Pain Interference” measurement, those with advanced illness who receive care in any of the covered hospital types should have “Pain Interference” measured and treated with whichever treatment is most effective, including opioids when needed.
Request for Information (RFI) on NQF and CDC Opioid Quality Measures C-TAC noted that the three NQF quality measures listed evaluate patients without cancer with prescriptions for opioids combined with benzodiazepines, at high-dosage or from multiple prescribers. While these behaviors could suggest opioid misuse, it is also possible that some patients in this group could be receiving appropriate treatment under the management of a hospice or palliative care team. As such, those receiving hospice, palliative care or with advanced illness should be exempted from those measures.
To read the full comments, please click here.
For more information about C-TAC’s legislative and regulatory efforts, please contact Policy & Advocacy Manager Davis Baird at DBaird@theCTAC.org.