March 15, 2018: MGMA Responds to Ways and Means RFI on opioid epidemic

March 15, 2018   
 
The Honorable Kevin Brady, Chairman       The Honorable Richard Neal, Ranking Member       
Committee on Ways and Means                   ​Committee on Ways and Means  
1011 Longworth House Office Building      341 Cannon House Office Building
Washington, DC 20515                                Washington, DC 20515    
 
The Honorable Patrick Tiberi, Chairman       The Honorable Sander Levin, Ranking Member
Subcommittee on Health                                Subcommittee on Health
Committee on Ways and Means                     Committee on Ways and Means
1203 Longworth House Office Building       1236 Longworth House Office Building
Washington, DC 20515                                  Washington, DC 20515 
 
Dear Chairman Brady, Ranking Member Neal, Chairman Tiberi and Ranking Member Levin, 
 
The Medical Group Management Association (MGMA) commends the Committee and Subcommittee’s ongoing efforts to respond to the opioid crisis, including this request for information. Stakeholder engagement is critical to understanding how to most effectively address this growing epidemic. MGMA appreciates this opportunity to comment and looks forward to continuing to support the Committee’s important work of combating the nation’s opioid crisis.   
 
MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA has empowered medical group practices to create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in this country. 
 
Overprescribing/data tracking  

One of the tools most critically underutilized in the fight against the opioid epidemic is electronic prescribing (e-prescribing). E-prescribing of opioids would not only more easily allow providers to flag potential overuse or misuse for patients when they are prescribed by multiple practices or providers through real-time notifications, it would also facilitate the collection of data that could be studied and used to inform ongoing efforts to curb opioid overuse and misuse.  
 
E-prescribing of non-controlled substances was a required component of the Medicare and Medicaid Meaningful Use EHR Incentive Program and is currently required as part of the Advancing Care Information component of the Merit-based Incentive Payment System (MIPS). As a result, a high percentage of physicians use this approach to prescribe medications for their patients. Unfortunately, e-prescribing of controlled substances is obfuscated by a myriad of complex federal and state regulations and requirements that impose administrative burden on 
practices and hinder more widespread adoption. With many physicians forced to write paper prescriptions for controlled substances, the ability to identify patient overuse or misuse is significantly decreased and hinders automated data collection. We urge Congress to work with the administration to simplify federal e-prescribing requirements and harmonize them with state requirements. 

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