In a Draft Call Letter issued February 1, 2018, the Centers for Medicare & Medicaid Services (CMS) announced that it is considering a number of new strategies to address opioid overutilization within the Medicare Part D program. CMS is particularly concerned with chronic overuse among beneficiaries taking high levels of prescription opioids (e.g., beneficiaries prescribed opioids with a 90 morphine milligram equivalent (MME) dose or higher per day), beneficiaries with multiple prescribers, and “opioid naïve” patients (i.e., patients newly prescribed opioids).
CMS’s strategies include consideration of a 7-day supply limit for initial fills of prescription opioids for the treatment of acute pain, potentially paired with a daily dose maximum (e.g., a limit of 50 MME). According to CMS, this type of restriction may reduce the number of leftover opioid pills available to an opioid naïve patient, which in turn can reduce the risk that the patient develops an “affinity” for opioids that can lead to misuse and diversion. CMS also proposes that Medicare Part D sponsors implement formulary-level opioid safety edits at the point-of-sale (POS) at pharmacies of 90 MME, which could only be overridden by a sponsor, and which may be paired with a 7-day supply allowance for initial opioid prescriptions for the treatment of acute pain.
In support of its approach, CMS observes that at least 16 states have implemented restrictions on initial prescriptions of opioids in certain circumstances, including Connecticut, Massachusetts, Rhode Island and New York. CMS is soliciting feedback from stakeholders (especially Part D sponsors) on its proposals in the Draft Call Letter, including with regard to whether a 7-day supply limitation is appropriate, or whether an alternate limit (such as a 3-day or 5-day limit) and/or a daily dose maximum (such as 50 MME) may be more effective. Comments may be submitted to CMS until March 5, 2018, and a final version of the Call Letter will be published on April 2, 2018.