New limits for high-dose opioid prescriptions will be enacted next year for Medicare Part D users, the Centers for Medicare & Medicaid Services (CMS) announced on April 2. Prescriptions will be held to a standard of 90 morphine equivalent milligrams (MME) per day, which follows the CDC prescribing guidelines for primary care physicians released last year.
The Medicare announcement—part of the 2019 Medicare Advantage and Part D Rate Announcement and Call Letter—also sets limits for opioid-naive patients on seven-day prescriptions, and notes the expansion and combination of the Overutilization Monitoring System and other government facets to identify “high-risk” opioid users, defined as using high levels of opioids from multiple sources, and “potentiator” users, who are using other medications (e.g., benzodiazepines) that increase the risk for adverse effects from opioids. CMS also plans to increase education on overdose risk and prevention.
With around 42.8 million people enrolled in Medicare Part D as of 2017, and a precedent for setting industry example, the agency hopes to “address the opioid epidemic” with these limits, aiming for an “overall reduction in opioid overuse and overdoses.”
The limits will not affect patients in long-term care facilities, hospice, palliative care or those effected by cancer-related pain. It also excludes patients seeking medication-assisted treatment for opioid addiction, such as those on buprenorphine.
Some research has shown higher doses can be correlated with overdose. A Veterans Health Administration sample of chronic pain showed overdose patients had an average dosage of 98 MME per day, compared with other patients who had an average of 48 MME per day. The CDC also said an opioid dosage at or above 50 MME per day doubles the overdose risk, compared with dosages less than 20 MME per day. The standard of 90 MME per day now set by Medicare is equivalent to 90 mg of hydrocodone per day, 60 mg of oxycodone or about 20 mg of methadone.
But the average number of daily MME per prescription has been declining, from 60 to 50 MME per day between 2006 and 2015, according to numbers from the CDC. Those with high-dose prescriptions (≥90 MME per day) also have declined, to an average 6.7 per 100 people in 2015. And overall prescriptions are down, at around 70 per 100 persons that same year, although that number is still three times higher than in 1999.
we know that opiate prescriptions have been declining annually since 2012 and they are using TWO YEAR OLD DATA – 2015 and using generally accepted national averages upward to 10% of the population could be classified as suffering from incurable intractable chronic pain – requiring 24/7 opiate therapy. With the CMS quoted numbers – using 2015 data – they believe that with 30% of that group of pts being untreated properly is STILL TOO HIGH..
CMS is also using opiate conversion ratios that are stated as.. FACTS … where are in fact… “HIGHLY CRUDE ESTIMATES”… and apparently there is no pt accommodation for the pt being fast/ultra fast opiate metabolizer.
Here is four quotes from the CDC opiates guidelines:
https://www.cdc.gov/mmwr/volumes/65/rr/rr6501e1.htm
“The guideline is intended to ensure that clinicians and patients consider safer and more effective treatment, improve patient outcomes such as reduced pain and improved function.”
“Clinicians should consider the circumstances and unique needs of each patient when providing care.”
“Clinical decision making should be based on a relationship between the clinician and patient, and an understanding of the patient’s clinical situation, functioning, and life context.”
“This guideline provides recommendations for primary care clinicians who are prescribing opioids for chronic pain outside of active cancer treatment, palliative care, and end-of-life care.”
It would also appear that CMS’ recommendation COMPLETELY IGNORES the above parts of the CDC opiate dosing guidelines.
It would also appear that CMS is dead set on discriminating against a segment of our society that is consider a “protect class” under the Americans with Disability Act and the Civil Rights Act. Since the federal agency that is in charge with enforcing the ADA https://www.ada.gov/filing_complaint.htm is under the same agency as the DEA – Dept of Justice. AND… since CMS and CDC are part of HHS…
Is it just me… or does there seem to be a great deal of collusion and cross protection of the actions of various Federal agencies by other Federal agencies ?
Filed under: General Problems
I have been taken down all the meds over the last two years and pain has gone thru roof quality of my life has fallen. since my second reduction I have fallen four times broke my tail bone. then in my pain doctors waiting room I was seated and got up when my name was called and fell down broke my right fibula and tibula . then later my right knee and I cannot recall how it happened has a 100 percent torn menicias and yes even with all that meds continue to be lowered. I begged cried to no avail. I am in constant pain live is so difficult for me and depression is present sometimes world seems bleak. I want to enjoy things I want to enjoy my kids gkids but get worn out tired and no fun. I was at pain doctor yesterday and was told another reduction is in order. I again pleaded offered my reasons to closed ears and non caring doctor. I fell so rejected by the health care . this has got to change.
90 mgs.per 24 hrs.?I will be vomiting,uncontrolled bowels,delirium tremens,just to scratch the surface.One size fits all!Does Jesus forgive suicide?Here’s the really trashed part of it all.If I have ANY trace of my pain meds,-Drpo dead from cardiac arrest.they’ll say “opiod O.D.”rear ended by a car?”opiod O.D.”Fall from a height?”opiod O.D.”Burn to death in an unescapeable home or car fire?”opiod O.D.”Get the bends from rising scuba too fast?”opiod O.D.”Die in an airline crash?”opiod O.D.”Fall from my horse and get pitched into a 2×6’fence rail?”opiod O.D.”n’am sayin?na’m sayin?n’am sayin? n’am sayin?n’am sayin?na’m sayin?FUCK. 3 day wait in Fla.to get you a .38.glock,357,22,44mag.etc.Oh,wait!Cant buy a bump stock anymore,that oughta make it harder for school gun rampages….They got no trouble w/you gettin a piece,but DONT YOU DARE TO TRY TO GET A TABLET FOR YOUR CHRONIC PAIN!!!YOU SCUM!!HOW DARE YOU BE SICK????.Tell me your reply to that,Bill Nelson,Marco Rubio!I’ll be right here,staring at the ceiling at 4 a.m.in tears and agony.I aint goin nowhere!
It does sound like blatant diacrimination. So why won’t the ADA support Chronic pain patients??
The answer is very simple… the agency that enforces the ADA and Civil Rights laws is part of the DOJ (Department of Justice) as is the DEA… chance of one Federal agency going after another Federal agencies for violating the laws ?
What a mess and with the DOJ and their troubles lately we are destined to not be heard~ I for one plan on doing anything and everything I can to be heard~ Not only for me but for you~ I am great at speaking and look fine . Is there a place I can write to try and set up a time to speak to Congress? I do have a Doctor who would come with me and if you would also and anyone else we can get would help~
I am sincere about tackling this and feel I always had something I could use my good speaking abilities to use in and this would be it~
Thank you Kindly for your time Dr. Steve!
Sounds like blatant discrimination against legit chronic pain patients and medical malpractice to me. It also violates the Hipocratoc Oath that physicians should do no harm.
If these new rulings are intended to follow the CDC prescribing “GUIDELINES” for PRIMARY CARE physicians, pain management specialists should be able to overrule these CDC and CMS restrictions and continue prescribing opioids for true chronic pain patients as they have continued to prescribe for them.
Chronic pain is a very real disease and Complex Regional Pain Syndrome has been rated on the McGill Pain Index as MORE painful than CANCER and amputation and childbirth … and a whole lot more. These patients suffer from a “suicide disease” that drives far too many people to the brink of death due to 24/7 burning and debilitating pain that restricts their function and ruins their quality of life. Even though CRPS patients, some 200,000 in the US, are not living in hospice or palliative care centers, they deserve the same opioid pain treatments as those suffering with cancer.
From what I read the office a budgeting and accounting is recommending expanding the online data management program to all 50 states so so that Medicare, Medicaid and workers comp can track expenditures. Dr Neal Dunn of Florida is pushing legisllesgisto put the veterans administration on line under the quise of saving the veterans from addiction. The reality of the whole CDC guidelines is beginning to appear as a way to justify having a computer monitoring system for cost for all governmental programs. One of those things that the government can but should they? The answer is yes they can but no they shouldn’t!
Why bother? I feel as if I cannot belive a word–talk about: ‘swivel-head!!!’ Are these guidelines changed or not???? This feels like such an insulting game….
As far as collusion,,of course,,,there is collusion w/insurance companies and our government,,there is collusion w/all the dea,fda,cdc,hhs etc,,,and collusion is illegal it violates over 14 different constitutional amendement..Collusion,, of course there is,,,because this all reeks of corruption and corrupt regimes have no use for truth or law,,As T.J puts it,,,”When any government evinces BY DESIGN to reduce its citizens to absolute despotism,,it is our right, our duty to alter or abolish it,,” This is why it is lawfully writting in the founding father laws that govern our country,,,of course its collusion and illegal!!!maeyw
Ok so NOW, starting next year my medication will be dropped to next to nothing. Do you are telling me tgst there is no hope for legitimate chronic pain patients? Since my fentanyl was reduced involuntarily by 3/4 overnight forcing me to go through withdrawal…for what? I NOW have no quality of life and NOW as of April next year, the severe pain I am.in will be a 1000 instead of the measly 100 on a pain scale of 1-10…. There is no hope…wow, why don’t they just give out loaded guns to us all because essentially that is what they are doing. There is NO offer to help with other modalities that might help slightly with the pain so this is another way to kill off a heck of a lot of people… My kids are grown, they don’t need me anymore. I have no quality of life and Now you are saying it will get worse….thanks for the warning, now I can prepare.
I know how you feel! I too have grown children and now they will not come and see anymore because I am stuck in bed most of the time with depression.
Suicide has crossed my mind but instead I am going to TRY and get to talk to Congress and I will talk to anyone who will listen!
Try and hang in here because though I do not know you my heart aches for you and I will pray for you. I know people say they will pray BUT I DO~
Hugs and May God carry you and us through this!
Linda
Sally; I’m so sorry…I know something of what you’re feeling, except I never had any kids, other than the fur ‘n’ feathers type. I do have an emotional support dog that is my reason to go on. i find myself thinking things like “he’s 5 now, probably has 9 more years. I have to make it that long.” One more insane thing is, when he gets older and is in pain, I’ll be able to provide him with better quality of life, unlike what the guv is doing to us.
It’s obscene…
Wait a minute,,,I though this was stopped,,and it was going to be 200 me??Did they change their mind for some reason,,knowing their not going to be sitting a court of law for breaking numereous laws and constitutional laws??maryw
I assume they must have changed their mind if you heard that. Ugh.
90mme does not have the same effect on pain for every patient. Pharmacogenomic evaluation of tramadol, tylenol 3, percocet, hydrocodone, are affected by whether a patient is an ultra fast metabolizer or a poor metabolizer of opioid drugs. I can provide supporting documentation if you want. rx-consultant@dublin.com.
I am a fast metabolizer in some meds and slow in others BUT my CMS pain management doctor who is older than the hills and says so himself does not believe in any of that~
Also why is this CMS supposed pain management doctor who is an Internal Medicine Doctor ruining my life by doing this without me knowing him and my regular doctor who is a Internal Medicine doctor right in the same area and treated me for over 20 years for my Osteogenesis Imperfecta which is a Brittle Bone and Loose Ligaments and Joints Genetic Disease since birth?
I feel my regular doctor MAY give me my meds WAIT NO because their clinic is closing and losing money and they were told by the CEO to get everyone off their Opioids and Benzos~
No hope for me
Linda