ACAP Comment Letter on Use of Pharmacotherapy for Opioid Use Disorder Measure

May 10, 2017

To: Whom It May Concern

Re: Quality Measure Development and Maintenance for CMS Programs Serving Medicare-Medicaid Enrollees and Medicaid-Only Enrollees, contract number HHSM-500-2013-13011I, Task Order #HHSM-500-T0004. – ACAP Support with Modifications

Submitted via
Measure Name: Use of Pharmacotherapy for Opioid Use Disorder
Level of Support: Support with modifications

The Association for Community Affiliated Plans (ACAP) represents 60 Safety Net Health Plans that cover more than 17 million people through Medicaid, CHIP, Medicare, the Marketplaces and other publicly-sponsored health programs. Our plans cover nearly half of all people in Medicaid managed care, and are on the forefront of innovative efforts to reform health care, especially health care for people with low incomes. We thank you for this opportunity to comment on the proposed measures for dual-eligible individuals entitled “Use of Pharmacotherapy for Opioid Use Disorder.”

ACAP and our member plans recognize the importance of providing timely access to MAT. While we support the concept behind this measure, we can only support this measure with modification.

General Questions

  • Is the candidate measure useful for measuring important domains of quality for the Medicaid population?

As noted above, we do believe there is a need for this measure in order to increase timely MAT referrals. However, this measure can only be supported at the state level and not as a plan measure. First, there is the issue of carve outs. Given that many states carve out all or some substance abuse treatment, including Methadone treatment, any plan measurement would not be useful on a national level because it would not be an apples-to-apples comparison. Second, in many cases due to carve outs and limited sharing of data associated with 42 CFR Part 2 restrictions, the state is often the only entity that has access to all SUD MAT data. Finally, many MAT treatment restrictions are based on benefit limitations determined at the State level and are not under the health plan’s control. Therefore, while we support the measure at the state level, we cannot support this as a workable measure at the health plan level.


Additional Measure Specification Questions

  • How frequently are non-FDA approved drugs prescribed as treatment for OUD? Should we include these drugs in the measure? FDA-approved drugs are methadone, buprenorphine/naloxone –oral and extended release, and naltrexone –oral and extended release.

We do not have data on the use of other non-DDA drugs for SUD treatment. However, we oppose including such drugs in the calculation of this measure since it would it would be extremely difficult to track and trend off-label use. We strongly support limiting this measure to the FDA recognized drugs for SUD treatment.

  • How might measure performance and reliability vary under different continuous Medicaid enrollment criteria (e.g., 12 month vs less than 12 month enrollment in Medicaid)?

We do not support using a shorter enrollment timeframe. Unlike other conditions, it is well-recognized that it is often difficult to convince individuals to enter into drug treatment. We believe this evolution in care would be missed if anything shorter than a 12 month enrollment timeframe were used for this.

  • Should the denominator be expanded to include beneficiaries with only a diagnosis of opioid use (i.e., without a diagnosis of opioid abuse or dependence)? If yes, what is the rationale?

We do not support expanding the denominator to include beneficiaries with only a diagnosis of opioid use. First, it is unclear how this would be defined. Second, it is unclear how appropriate use of opioids that do not require MAT would be separated from opioid use where MAT is appropriate.

Thank you for this opportunity to comment on this measure. If you have any questions or comments on this response, please feel free to contact me at




Deborah Kilstein
VP Quality Management and Operational Support

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