AmeriHealth Caritas appreciates the opportunity to provide comments on the Safe Use of Opioids – Concurrent Prescribing measure. With more than 30 years of experience, AmeriHealth Caritas is one of the nation’s leaders in health care solutions for those most in need. Operating in 17 states and the District of Columbia, AmeriHealth Caritas serves more than 5 million Medicaid, Medicare and CHIP members through its integrated managed care products, pharmaceutical benefit management and specialty pharmacy services, behavioral health services, and other administrative services.

AmeriHealth Caritas supports the intent of this measure to address an important public health crisis, however, we offer several suggestions to the measure developers to help strengthen the specifications:

• Expand the list of opioids to include any Schedule II, III, and IV opioid medications. Tramadol is a Schedule IV opioid medication and is commonly prescribed opioid. We believe it is important to include Schedule IV opioid medications in the definition of “opioid medication” as these drugs can still pose risks when prescribed currently with a benzodiazepine.
• Expand the list of exclusions beyond cancer and palliative care to include certain chronic conditions such as sickle cell where it may be clinically appropriate to be prescribed concurrent opioid medications.
• Ensure that prescribers check the state Prescription Drug Monitoring Program (PDMP) database as part of the measure. Based on information in the database, even a single opioid prescription could represent overlapping therapy.
• Address potential unintended consequences of this measure that may result in modifying on-going outpatient drug regimen in an effort to improve the measure score. For instance, if a patient has been on long term therapy with either benzodiazepines and/or opioids and is unable to obtain these medications from the facility, they may go into abrupt withdrawal and seek illicit drugs such as heroin.