AANA, as part of the Voices for Non-Opioid Choices Coalition, wrote to CMS recommending that the Medicare Hospital Outpatient Prospective Payment (HOPPS) and Ambulatory Surgical Center Payment Systems CY 2020 proposed rule does not do enough to appropriately incentivize the utilization of all evidence-based, medically appropriate non-opioid pain management approaches, especially for patients treated in the hospital outpatient (HOPD) setting.

Voices for Non-Opioid Choices, of which the AANA is a member, is a coalition seeking to increase patient access to non-opioid therapies and approaches to managing pain. The letter also said that last year, CMS wisely adopted a policy change that would provide separate reimbursement for pain management approaches provided to patients treated in an Ambulatory Surgery Center (ASC). This was a welcome change that appropriately incentivized the utilization of non-opioid therapies. Unfortunately, because the majority of surgeries performed in the United States every year occur in a HOPD setting, the draft rule does little to ensure that these patients can access available pharmacologic and non-pharmacologic non-opioid approaches to alleviate pain. Given that the majority of these procedures – and associated opioid prescribing – take place in the HOPD setting, we urged CMS to revise the current draft to adopt policies that better incentivize the utilization of non-opioid approaches for patient pain management.

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