The CME Coalition has submitted comments to the Centers for Medicare and Medicaid Services (CMS) applauding their proposal to reward physicians for their participation in certain continuing medical education (CME) activities. Under the proposal, quality improvement continuing medical education (CME) would be recognized as a Clinical Practice Improvement Activity (CPIA) under the new Merit-Based Incentive Payment System (MIPS) — a physician reimbursement system created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). As detailed in the proposed rule (pg. 1042), CMS recommends that “completion of an accredited performance improving medical education program” be included under the list of CPIAs under MIPS — one of the key policy changes proposed for the Quality Payment Program Year 2.

​Nearly 100 million people in the United States, or roughly one-third of the population, experience some form of chronic pain. Meanwhile, prescription opiate abuse and addiction have reached epidemic proportions in the United States, including the widespread illegal diversion of prescription opioids for street use, which in turn can increase the rates of abuse of illegal narcotics. Some clinicians have also prescribed opioids without adequate training surrounding their abuse potential. Many primary-care providers have recently become reluctant to prescribe opioid pain relievers in the context of current public health concerns surrounding addiction, which leads to some chronic pain patients now going without any appropriate treatment. 

On May 3 and 4, 2017, the Food and Drug Administration (FDA) convened a public workshop (agenda) examining “Training Health Care Providers on Pain Management and Safe Use of Opioid Analgesics.” Andy Rosenberg presented testimony on behalf of the CME Coalition, in which he spoke to the role of CME in opioid prescriber education. Among the key points made in Andy’s remarks, "FDA should continue to rely on accredited CME as a vital tool in prescriber education in the opioid space. The strength of CME is that it can produce myriad educational activities that are targeted to physicians based on their professional practice gaps, individualized needs, and stages of learning and change. Added flexibility will allow prescriber education to better address individual prescribers’ educational and practice needs... Finally, as an incentive for prescribers to participate in opioid REMS, we recommend that the FDA encourage CMS to include opioid REMS as an improvement activity in the Quality Payment Program MIPS.”

On February 27, 2017, the CME Coalition responded to a "call for activities" from the Centers for Medicare and Medicaid Services (CMS) on activities for inclusion in the list of acceptable Clinical Practice Improvement Activities (CPIA) under the new Medicare physician payment program known as MIPS. The proposals outline how quality and performance improvement CME have a direct impact on improving clinical practice and patient care. 

The CME Coalition has submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the agency's final rule regarding the definition of practice improvement activities in the implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Following the Coalition's comments on the proposed rule, the Coalition again asks that CMS continue to explore the potential role that continuing medical education (CME) can play as a clinical practice improvement activity. In its final rule, CMS acknowledged public comments encouraging the inclusion of CME as an improvement activity under the MACRA regulatory regime, and the CME Coalition hopes to work with CMS in order to include CME in the 2018 proposed fee schedule. In explaining its request, the CME Coalition notes that CME is "a leading means by which physicians, develop and maintain the knowledge, skills, and practice performance that leads to imporved performance and optimal patient outcomes."

The comments in full are available below.