Subject: CMS-2017-0163, Advance Notice of Methodological Changes for Calendar Year
(CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D
Payment Policies and 2019 Draft Call Letter
Dear Administrator Verma:
The American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons
(CNS) appreciate the opportunity to review the opioid prescribing provisions of the above-referenced
Medicare CY 2019 MA and Part D Advance Notice and Draft Call Letter. We share the agency’s interest
in finding effective proposals to help address the opioid overuse and abuse problem in America.
One of the concerns raised in the Draft Call Letter is the notion of multiple prescribers providing opioid
prescriptions for a single patient. We support the tracking of this phenomenon where possible but wish
to explain a circumstance that arises in the treatment of our patients for which this scenario is medically necessary. Typically, chronic pain patients obtain their maintenance opioid prescriptions from either a
pain physician or primary care prescriber. When patients undergo surgery, however, they receive a
short-term opioid prescription from their surgeon for their postoperative pain, which is distinctly different
than the chronic pain for which they are being treated with maintenance opioids. While one could argue
that the postoperative pain medication could be provided by the pain or primary care prescriber, only the
surgeon has sufficient knowledge of the invasiveness of the surgical procedure to assess the
postoperative pain medication requirements accurately. It would be unduly burdensome to both patients
and prescribers if providing a crucial opioid prescription for acute postoperative pain triggers an alert and
subsequent denial of either the postoperative or chronic maintenance opioid prescription. There should
be a system in place to allow for the immediate approval of postoperative opioid prescriptions as needed
at the time of dispensing.
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Read full letter here
