On July 28, the American Society of Addiction Medicine (ASAM) submitted comments on the Center for Medicare and Medicaid Services (CMS) Value in Opioid Use Disorder Treatment (Value in Treatment) Demonstration design. The 4-year demonstration program was authorized by section 6042 of the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act). The program would establish two new payments for opioid use disorder services furnished to applicable beneficiaries participating in the demonstration program: a care management fee and a performance-based incentive.

ASAM’s comments praised the development of the program, while also identifying various changes that would improve it. The comments applauded the performance measures CMS identified for the program, but noted that emergency department utilization might be influenced by factors outside of a participant’s control. Therefore, CMS should risk-adjust that specific performance measure. ASAM then urged CMS to delay the performance-based payments in the program for two years to encourage participation in the program without penalty. Finally, given the uncertainty and intense pressure on clinicians due to COVID-19, ASAM recommended that CMS extend the application deadline for the program beyond September 30, 2020, perhaps through a rolling admissions process or implementation of multiple deadlines.

Read a summary of the program here. 

Read ASAM's comments here.