Medicaid Call to Action
August 28, 2012
Dear Friend,
This is an urgent call to action needed by September 4 at 5:00 PM ET.
Right now Medicaid proposes a change their Rules to allow CRNAs (Certified Registered Nurse Anesthetists) to expand their scope of practice to include diagnosing, treating, and prescribing for chronic pain away from a surgical setting. Responding to the Affordable Care Act, this proposed change is designed to immediately meet the increased need for clinicians providing pain care services. The National Fibromyalgia & Chronic Pain Association (NFMCPA) opposes this Rule change based on lack of education, training, and clinical experience of CRNAs to manage a person’s complex medical care for chronic pain.
· CRNAs are trained and currently licensed to administer anesthesia (during surgery) or acute pain medications (in hospital/recovery rooms after surgery).
· CRNAs are educated and have clinical experience for the central nervous system and anesthetics.
· Medical doctors are educated, trained and have clinical experience for the whole body as well as prescribing medications.
· Medical doctors are trained to examine, diagnose, and develop long-term treatment/recovery plans including adjunct therapies and/or medications.
More qualified healthcare professionals (HCPs) are needed to help people requiring chronic pain care. Diagnosing and treating chronic pain is a complex medical issue from person to person, different than a person receiving standardized care for strep throat or a broken arm.
The NFMCPA respects and values the role of CRNAs in appropriate health care settings. But we are very concerned about a proposed change in the Medicaid Rules to permit CRNAs to diagnose, treat, and prescribe medications for people in chronic pain. The NFMCPA believes this proposed change (1) is a disservice to people utilizing Medicaid; (2) will needlessly prolong or increase suffering; and (3) spend significant healthcare system dollars without benefitting the people who need these services most.
We encourage you to act today by writing to CMS (Centers for Medicare and Medicaid Services) to let them know you do not want them to change their Rule to allow CRNAs to diagnose and treat chronic pain.
Below is draft language for your consideration in writing a letter to CMS. The proposed Rule change can be found at www.fmcpaware.org/CMS-Rule-Change.
Thank you for stepping forward and making a positive difference. A loud response matters, and your voice counts!
Sincerely yours,
Jan Favero Chambers, President
National Fibromyalgia & Chronic Pain Association
Draft language:
“I appreciate the opportunity to offer comments on the proposal for "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 am a person who suffers from chronic pain, and I have serious concerns with the proposal from CMS to create a national policy that is not in my best interest.
I respect the role of nurses in the health care setting, but I firmly believe that nurse anesthetists should not engage in diagnosing and treating chronic pain as they lack the education, training, and medical experience of a physician. Chronic pain is a unique condition still misunderstood by many in the health care community. Health care professionals who treat patients with chronic pain must know how to diagnose the painful condition and determine which treatments may help to lessen pain and increase function. Equally important is understanding the psychology of pain, as well as its personal and social impacts. People with chronic pain are often desperate to find a cure, but if a procedure is performed unnecessarily or inappropriately, it can significantly worsen a patient’s pain condition and increase costs to the federal government, third-party payers and the patient.
Given the unique physiology and experience of chronic pain, CMS should only pay qualified physician health care professionals who have the education and training necessary to diagnose and treat chronic painful conditions. I urge you to reject this portion of the proposed rule and help to ensure that patients with chronic pain continue to have access to the highest quality of care.”
This letter may be delivered in one of four ways:
DATES: Comment date: To be assured consideration, comments must be received at one of the addresses provided below, no later than 5 p.m. Eastern Time on September 4, 2012.
ADDRESSES: In commenting, please refer to file code CMS-1590-P. Because of staff and resource limitations, CMS cannot accept comments by facsimile (FAX) transmission.
You may submit comments in one of four ways (please choose only one of the ways listed):
1. Electronically. You may submit electronic comments on this regulation to http://www.regulations.gov/#!submitComment;D=CMS-2012-0083-0075. Follow the instructions for ``submitting a comment.''
2. By regular mail. You may mail written comments to the following address ONLY:
Centers for & Medicaid Services
Department of Health and Human Services
Attention: CMS-1590-P, P.O. Box 8013
Baltimore, MD 21244-8013.
Please allow sufficient time for mailed comments to be received before the close of the comment period.
3. By express or overnight mail. You may send written comments to the following address ONLY:
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1590-P, Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850.
4. By hand or courier. If you prefer, you may deliver (by hand or courier) your written comments before the close of the comment period to either of the following addresses:
a. For delivery in Washington, DC—
Centers for Medicare & Medicaid Services
Department of Health and Human Services, Room 445-G
Hubert H. Humphrey Building
200 Independence Avenue SW., Washington, DC 20201.
