CMS Issues Alert for WCMSA Submission Guidelines in Response to DEA Decision to Reschedule Hydrocodone Combination Products
Jesse Hamby
November 21, 2014

On October 6, 2014, the Administration for the Drug Enforcement Administration (DEA) rescheduled hydrocodone combination products.  This was in response to the epidemic sweeping our Country because of the documented increase opioid abuse.  Consequently, these drugs were moved from Schedule III to Schedule II by the DEA as authorized under  the Comprehensive Drug Abuse Prevention and Control Act of 1970.   When a drug is moved up in the Schedule under this law, it is more difficult to secure.  As a Schedule II drug, an original prescription will be required before the drug can be dispensed.  Only a 30 day supply is allowed at a time, but the Provider can issue three separate prescriptions, with specific dates on which the product can be dispensed.  If the medication is needed beyond 90 days, a visit with the Doctor is required.

 
Click here to read the full notice.
 
In response to this change, CMS issued an alert to require a Medicare Set Aside allocation, effective January 1, 2015 to increase the number of healthcare provider visits for situations where such opioid medication is to be used over the long term.  This will increase costs for the MSA because of these increased visits.  To mitigate against this increaseexposure, we recommend our clients consider our pharmacy and peer to peer medical services to wean injured workers from this harmful medication.  There is no medical evidence to support the  benefit for long term use of these drugs. Recently, District Attorneys in Orange County California and Eastern Kentucky, have brought claims advocating this position against large pharma.   We believe such evidence, as it publically becomes available can help change the course of such unnecessary treatment that will benefit both the long term health of the injured worker and reduce the cost of the proposed allocation.
 
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Click here to read the full Alert.