AHIP Responds to Proposed CDC Opioid Prescribing Guidelines

AHIP has responded to the latest updates to opioid prescribing guidelines from the Centers for Disease Control and Prevention (CDC).

CDC’s proposed updates to the opioid prescribing guidelines were published on the federal register on February 10, 2022, with a comment period lasting through April 11, 2022.

AHIP voiced support for the updated guidelines’ overarching goals. In particular, the organization expressed support for the guidelines’ emphasis on improving provider-patient communication, the reduced emphasis on opioid prescription and tapering thresholds, and the bolstering of whole-person care and coordinated care.

The payer also supported the updated protocols’ decision to center members’ needs and goals.

“In many discussions regarding opioid use, health insurance providers have stressed the importance of evaluating what outcomes a patient seeks to achieve from pain treatment, considering nonpharmaceutical and non-opioid options, and appropriately communicating with patients about what can and cannot be accomplished through a prescription for opioids,” AHIP shared.

The organization pointed out that payers offer a wide variety of non-opioid and non-pharmacological pain management supports. For example, some payers have expanded coverage for physical therapy and chiropractic care.

Acupuncture is another alternative to opioids for pain management, AHIP noted. CMS recently finalized a rule supporting Medicare coverage for acupuncture. However, some studies show that many commercial payers have lagged on covering acupuncture.

Lastly, AHIP echoed the guidelines’ demand for a greater wealth of research on opioid prescribing and related subjects from diagnostics to the outcomes of opioid-related stigma.

“AHIP and its members agree that there is a need for research to enhance existing risk assessment tools and to inform future evidence-based clinical guidelines on dosing and treatment options to manage various types of pain,” the comment letter stated.

However, the payer organization also included six recommendations for CDC to consider.

AHIP suggested aligning with performance quality measures from organizations such as National Committee for Quality Assurance (NCQA). 

For instance, in September 2021, NCQA released Health Plan Ratings that included three quality measures to assess how plans handled the opioid crisis. The measures were avoiding high dosage, avoiding prescribing from multiple prescribers and pharmacies, and avoiding long-term opioid use.

AHIP urged collaboration between CDC and quality measure organizations like NCQA to create a more unified approach to assessing quality in this opioid prescribing.

Second, the payer organization suggested that CDC recommend co-prescribing naloxone to improve the outcomes of tapering.

Third, AHIP called for more specific, rigid language around the appropriate size of an opioids prescription. This part of the updated guidelines departed from previous, more stringent versions.

“While we support providing flexibility and encouraging providers to prescribe responsibly given the risks of overdose and diversion, a strict limit in this specific circumstance may be appropriate,” AHIP advised.

Fourth, AHIP suggested that CDC’s guidelines around toxicology assessments be reframed to underscore how important these tests are in confirming substance abuse and to support providers’ decisions to conduct spontaneous assessments.

Fifth, AHIP found that the guidelines were not completely aligned with all of the federal guidance around opioids and highlighted certain departures in the proposal. Specifically, CDC should align the definition of what constitutes opioid overdose risk and the right conditions for prescribing naloxone.

Finally, AHIP recommended loosening highly restrictive language around the continuous use of high-dose opioids. The payer organization reasoned that such extreme measures may be necessary for a certain member population. In such populations, members would benefit from ongoing risk/benefit analyses as they progress in treatment.

“We encourage CDC and other stakeholders to empower health insurance providers, as well as clinicians and other stakeholders, to help coordinate and collaborate on appropriate care for patients experiencing pain and those who may be prescribed opioids,” the letter concluded. 

“While the revised Guideline increases inclusion of multi-stakeholder teams, policymakers and other authorities can further detail which groups can be effective in promoting evidence-based care and in which circumstances.”