We understand the spirit of making this change as cancer is not always painful and cancer diagnoses often persist beyond active treatment and remission periods.  There is also a growing number of people that are cancer survivors but continue to be treated with high dose opioid therapy titrated to current levels when they were experiencing significant pain but has never been successfully tapered and they’ve not been included in LTOT metrics.

As for cancer related pain diagnoses, we agree that when pain emerges as a symptom it will not appear as an ICD code until there is a level of permanence such as nerve damage, tissue damage, and pain related to treatment and drug-induced, chemo, radiation, and surgical consequences of treatment that become permanent conditions.

Due to the above, you may be inappropriately including Active Cancers (e.g., bone, pancreatic, large tumors that put pressure on soft tissue, etc.) known to cause significant pain. Have you considered including specific cancer diagnoses, and active cancer treatment in addition to cancer related pain diagnoses for this exclusion?