On September 27, ASAM submitted its comments on the 2020 Medicare Physician Fee Schedule (MPFS) proposed rule. While the MPFS proposed rule contains many different provisions, ASAM focused on two areas in particular. First, the MPFS proposal would create two different bundled payment models, one for outpatient treatment of opioid use disorder (OUD) and one for services rendered by opioid treatment programs (OTPs). ASAM’s comments applaud CMS for the creation of the models, while also noting that there are significant modifications that could be made to better serve patients and their treatment teams. ASAM believes that CMS should finalize these proposals, but with modifications, especially in the case of the OTP bundle regarding the payment amounts, definitions of covered services, and various other issues.

Second, the MPFS proposed rule contains language that would permit CMS to revoke or deny Medicare enrollment for physicians and eligible professionals who were the subject of prior action from state oversight entities with underlying facts reflecting improper physician or eligible professional conduct that led to patient harm. ASAM's comments stress that decisions surrounding a physician or eligible professional’s ability to practice should be determined by their personal physician and the state’s medical licensing board. ASAM urges CMS not to finalize its new proposal to deny or revoke enrollment for any action a state medical board takes, or, at a minimum, narrow the scope of this exclusion to avoid targeting state-mandated abstinence or substance use disorder treatment.

Read ASAM's comment letter here.