<p>I will try to weave these elements together as best as I can. I’m sorry the explanation is long. My understanding emerged from reviewing roughly 4 separate documents from CMS, 5 to 7 email exchanges with CMS staff, plus “real world” reports from a commercial pharmacist, 50% of whose practice is tied to pain and addiction patients. I have added some key excerpts as items A through E in this post.</p>
<p>Let me restate the core concern first, however. CMS is proposing to expand ongoing policies that it believes will implement the objectives central to the 2016 CDC Guideline on Prescribing Opioids for Chronic Pain. They posted an <a href="https://www.cms.gov/Medicare/Health-Plans/MedicareAdvtgSpecRateStats/Downloads/Advance2018.pdf" rel="noopener ugc nofollow" target="_blank">Advance Notice</a> on February 1. CMS will accept public comment to
[email protected] until March 3, 2017, a short 4-week comment period.</p>
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