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Full-Spectrum Prevention

SAFE Takes analyzes and assesses the federal recommendations and proposals made by the White House and National Governors Association.

SAFE Takes reflects our analysis and assessment of the progress made in each of the recommendations made by the President’s Commission (Commission) on Combatting Drug Addiction and the Opioid Crisis (November 2017) and the National Governors Association’s (NGA) Recommendations for Federal Action to End the Nation’s Opioid Crisis (January 2018). The following SAFE Takes focuses on government action pertaining to full-spectrum prevention efforts.


NGA:  Continue to coordinate with existing prevention programs in schools and avoid increasing stigma and fear around punitive approaches for those who need access to treatment. Expand federal support for new and additional resources to support training officers in schools, community engagements, and other educational activities.


Limited Infrastructure
This recommendation will largely be helped by implementing universal screening programs for students, in addition to supportive environments and activities to keep students out of triggering situations for return to use. Funding without the infrastructure to support long-term prevention and support for those in recovery will reap few benefits. Our SAFE Campuses program will work to support and provide opportunities for those in recovery in higher education.

Commission #18: The Center for Medicare & Medicaid Services (CMS) should remove pain survey questions entirely on patient satisfaction surveys so that providers are never incentivized for offering opioids to raise their survey score. The Office of National Drug Control Policy (ONDCP) and Health & Human Services should establish a policy to prevent hospital administrators from using patient ratings from CMS surveys improperly.

Slow Progress

According to research (such as this December 2018 study or this May 2017 study) it has been difficult to find agreement on what the right measures are for patient satisfaction and health outcomes, especially as they relate to propensity for opioid misuse.

However, in August 2018, CMS announced a proposal to remove pain management questions from the HCAHPS Survey in response to the President’s Commission. In July 2019, they also proposed removing pain question #10 from all HH CAHPS Surveys, but it was announced in November of 2019 that CMS would not be finalizing the removal of question #10 because of consumers gathered during the public comment period.

Research in these areas is key; ensuring that patients have access to the right treatment, rather than the easiest and cheapest treatment, which matters to the long term wellness of the patient.

NGA has a long history of working with states to tackle complex issues, including opioids. Their leadership helps states develop public policy options, and helps identify what is working in other states. Analysis of which states have policies that correspond to removing pain survey questions, as well as an analysis of what is working or not working would be helpful. The states then adopt their own state policy and regulations to align state systems with federal regulations.
The bureaucracy around changing state policy, internal systems, and effective implementation of those changes will slow this down.

Commission #19: CMS should review and modify rate-setting policies that discourage the use of non-opioid treatments for pain, such as certain bundled payments that make alternative treatment options cost prohibitive for hospitals and doctors, particularly those options for treating immediate post-surgical pain.


Attempts Have Fallen Short
There are few provisions for alternative pain treatments across federal and private insurers. Some states are convening “Payors” councils to examine service definitions and establish payment mechanisms. CMS included in its 2018 Roadmap: Strategy to Fight the Opioid Epidemic a plan to “disseminate best practices for state Medicaid agencies and other payers on alternative pain management strategies and other tactics to address the opioid crisis.” Although, reimbursement rates for alternative treatments remain an under addressed barrier to reducing opioid dependence.

A March 2019 Mandated Report to Congress, examined how the SUPPORT ACT called on the Medicare Payment Advisory Commission to identify incentives specific to the Medicare Inpatient and Outpatient Prospective Payment Systems that might encourage providers to choose cheaper opioid pain treatment strategies over other non-opioid treatment strategies.

In October 2019, U.S. Senators Jeanne Shaheen (D-NH) and Shelley Moore Capito (R-WV) sent a bipartisan urging HHS Secretary Alex Azar and CMS Administrator Seema Verma to address Medicare’s payment policies to ensure that health care providers are not incentivized to use opioid-based pain management treatments over non-opioid alternatives.