Grassroots Request to Contact CMS Today: Chronic Pain Medicine is the Practice of Medicine

REVIEW THE TALKING POINTS.

 The Centers for Medicare & Medicaid Services (CMS) has put forth a proposal to allow payment to CRNA's for the diagnosis and treatment of chronic pain. ASA is extremely concerned about this attempt to consider chronic pain management within the scope of practice of a nurse anesthetist.  In the name of patient safety, ASA will take a strong stance to make clear that chronic pain management IS the practice of medicine. Nurse anesthetists have neither the education nor the training to perform chronic pain services.  We need you to contact CMS regarding this proposal as published in the proposed rule for the 2013 Medicare Physician Fee Schedule: CMS-1590-P, "Medicare Programs: Revisions to Payment Policies Under Physician Fee Schedule, DME Face to Face Encounters, etc." The AANA has organized a letter writing campaign to CMS in support of the proposal.  It is important that the voice of medicine be heard.

Please follow the below steps to submit a comment to CMS.  Your comment must be submitted no later than 5 p.m. eastern time on September 4, 2012.  This submission process will include completing a government online form with your first name, last name, city, country, state, zip code, organization name, category.Using the copy and paste feature, you will be able to insert a message into the comments section as well as add any additional comments you feel are necessary. 

If you need any assistance with the comment submission process, please contact us at grassroots@asawash.org . Assistance with the process is also available from CMS via their ‘contact us’ feature at: http://www.regulations.gov/#!contactUs .

Please follow these below instructions step by step.

1. Click http://www.regulations.gov/#!submitComment;D=CMS-2012-0083-0075 to guide you to the comment submission area for this rule (CMS-1590-P).
   
   
2. In the left column, enter your first name in the noted space (Eg., John).
   
   
3. In the left column, enter your last name in the noted space (Eg. Doe).
   
   
4. In the left column, enter your city in the noted space (Eg. St. Louis).
   
   
5. In the left column, pull down country menu to 'United States'.
   
   
6. In the left column, enter your state in the noted space (Eg., Missouri or MO).
   
   
7. In the left column, enter your zip code in the noted space (Eg., 66314).
   
   
8. In the left column, enter organization name as “American Society of Anesthesiologists” or your own practice's name. 
9. In the left column, pull down category menu to the fourth option, 'physician---hc005'.
   
   
10. With your mouse highlight this bold text below:

    I appreciate the opportunity to offer comments on the proposal on "Certified Nurse Anesthetists and Chronic Pain Management Services" as put forward in CMS-1590-P - Medicare Program: Revisions to Payment Policies Under the Physician Fee Schedule. I must convey my serious concern with CMS' proposal to create a new national policy to pay for chronic pain services delivered by providers who have no formal education or training in this specialized area of medicine.

    Chronic pain procedures are inherently dangerous due to the anatomy and delicate structure of the spine and nerves upon which these interventions are performed. Complications can range from allergic reactions, infections and bleeding to nerve damage, spinal cord injuries (e.g. paralysis), and brain stem tissue damage. The risks associated with these procedures make it imperative that they be performed only when appropriate and only by professionals qualified to perform them.

    The stark reality is that nurse anesthetists do not have the appropriate education and training in chronic pain management. I agree with the Medicare contractor who wrote, "The assessment skills required for the evaluation of the chronic pain state and consequent therapy is not part of the CRNA training curricula."

    In the interest of patient safety, I resolutely believe that the current restrictions on nurse anesthetists providing chronic pain services are both appropriate and necessary and I urge you in the strongest possible terms not to adopt this proposed policy.

11. Now copy the text above. (In windows, you may highlight the text and then click 'control c' to copy the text, you may select 'copy' from the appropriate toolbar, or you may right click the text after highlighting it and select 'copy'. On a Mac, you may highlight the text and then click 'command c' to copy the text or you may also highlight the text and then click 'edit' on the top of the screen and select 'copy' from the pull down menu).
    
    

12. In the right 'type comments' section on the website, click in 'comment box' until you see the cursor.

13. In the right 'type comments' section 'paste' the copied comments from above into the 'comments box'. (In windows, you will click 'control v', you may right click and then click paste or you may click edit and select paste from the pull-down menu. On a Mac, click 'command v' or click edit on the top of the screen and select paste from the pull down menu.

14. Verify that the material 'pasted' into the comments section on the webpage is the same as the material you copied above. Please add any additional commentary that you feel is necessary.

15. Double-check the personal information you entered.

16. Click 'submit' located in the bottom right corner.

17. You will now be provided with a "comment tracking number." Please 'copy' and 'paste' the provided tracking number and email it to grassroots@asawash.org.

Learn more about this proposal.

THANK YOU FOR YOUR ADVOCACY EFFORTS!