Seema Verma, MPH, Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G
200 Independence Avenue, SW
Washington, DC 20201
Submitted electronically via www.regulations.gov
Subject: CMS-4190-P Medicare and Medicaid Programs; Contract Year 2021 and 2022
Policy and Technical Changes to Medicare Advantage Program, Medicare
Prescription Drugs Benefit Program, Medicaid Program, Medicare Cost Plan
Program, and Programs of All-Inclusive Care for the Elderly
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 opioid prescribing provisions of the above-referenced
notice of proposed rulemaking.
Implementation of Provisions of the SUPPORT Act
As CMS implements the Substance Use-Disorder Prevention that Promotes Opioid Recovery and
Treatment (SUPPORT) Act, we are particularly concerned that surgical and chronic pain patients can
continue to receive the care that they need. CMS has asked for public comment on reasonable
measures to assess inappropriate prescribing of opioids. We are eager to assist CMS as the agency
establishes its policy to direct Medicare Advantage (MA) plans to help identify patterns of inappropriate
prescribing while avoiding unnecessary harm and suffering for patients.
Read full letter here
