With the release of its 2017 draft call letter, CMS continues its push to curb opioid dependence, overdose and death among Medicare Part D enrollees. To that end, CMS proposes that Part D plan sponsors edit their benefit designs to target opioid overutilization at the point-of-sale. The letter also reminds Part D sponsors that benefit designs that impede medication-assisted treatment for opioid addiction, including high cost sharing, will not be approved by CMS.
The point-of-sale target is not a new proposal. CMS included an expectation in its 2016 draft call letter that Part D plan sponsors implement a soft point-of-sale edit to prevent improper opioid use. The recommendation was delayed, however, due to stakeholder concerns that enrollee access to needed prescription drugs could be disrupted.
Despite the commendable effort by CMS to reduce opioid use disorders and overdose, disagreement persists over Medicare Part D performance expectations aimed at enhanced utilization controls. For example, there has been significant pushback from stakeholders in response to recently solicited comments by CMS on whether providers should be required to consult a patient's history on their state's Prescription Drug Monitoring Program in an effort to identify the patient's risk of nonmedical use of controlled substances. Will this latest CMS proposal meet with similar opposition?
The deadline for submitting comments to the 2017 Draft Call Letter is March 4, 2016, and the final 2017 Call Letter will be published on April 4, 2016.
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