Subject: Request for Information (RFI) on the Development of a CMS Action Plan to
Prevent Opioid Addiction and Enhance Access to Medication-Assisted Treatment
Dear Administrator Verma:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we
appreciate the opportunity to comment on the above-referenced request for information (RFI) to assist
the Centers for Medicare & Medicaid Services (CMS) in its efforts to address opioid addiction.
Amid the nationwide opioid epidemic, physicians are under significant pressure to reduce opioid
prescribing in an effort to help resolve this widespread crisis. Yet patients continue to suffer from
undertreated chronic pain. Neurosurgeons stand ready to immediately address the opioid crisis by
providing several evidence-based and effective therapies to reduce the dependence of chronic pain
patients on opioid medications. Unfortunately, Medicare, Medicaid, and many private insurers often deny
the use of these treatments such as spinal cord stimulation, peripheral nerve stimulation, deep brain
stimulation, peripheral neurectomy, cordotomy and others despite substantial high-quality peer-reviewed
evidence supporting their efficacy in reducing chronic pain and patients’ dependence on opioid
medications. As a result of this dichotomy, neurosurgeons are thrust into situations in which they must
treat patients in pain while having fewer options available due to inadequate insurance coverage policies.
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