Submit your comments by 12-31

Submit your comments by 12-31

Quality and not volume should guide how our health care system values services.

The Secretary of Health and Human Services is trying to gain public comments on how to transform our healthcare system to one that pays for value as one of the top priorities of the Department of Health and Human Services (the Department or HHS).

As you will see, this is an issue on which the chronic pain community needs to weigh in.

Leave your comments w/ the federal government, here:

Unlike the traditional fee-for-service (FFS) payment system, which rewards providers for the volume of care delivered, a value-driven healthcare system is one that pays for health and outcomes. Delivering better value from our healthcare system will require the transformation of established practices and enhanced collaboration among providers and other individuals and entities. The purpose of this proposed rule is to modify existing safe harbors to the anti-kickback statute and add new safe harbors and a new CMP law exception to remove potential barriers to more effective coordination and management of patient care and delivery of value-based care that improves quality of care, health outcomes, and efficiency.

If we’ve learned anything from the readers of the National Pain Report about how they’ve been treated by physicians, it’s that often “they don’t listen to me because they’ve already decided what they want to do.”

Is your doctor being encouraged to prescribe you certain procedures or pharmaceuticals? That’s what the government is curious about (I think)

Here’s their “official language”:

This proposed rule is being issued by the Office of Inspector General (OIG) in conjunction with the Department of Health and Human Services’ Regulatory Sprint to Coordinated Care. Further, the proposed rule would add a new safe harbor pursuant to a statutory change set forth in the Bipartisan Budget Act of 2018 (Budget Act of 2018) related to beneficiary incentives under the Medicare Shared Savings Program and a new CMP exception for certain telehealth technologies offered to patients receiving in-home dialysis, also pursuant to the Budget Act of 2018.

Let’s discuss. Whatever you share w/ the government, please share with us in the comment section.

Thanks and Happy New Year.

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Authored by: Ed Coghlan

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Linda Royster

Pain management insists on doing medial branch trails once a year even though they are not successful. This procedure is merely a test to see if I get relief for 5 to 10 minutes, if so then that indicates a rhizotomy can be performed. I have occipital neuralgia and when the anesthetic is shot up it agitates the occipital nerves and it generally takes me three weeks to recover. This procedure is done once a year because Medicare will pay even though no success and I have voiced my pain. Same with CESI. I have had at least 16 and not one has relieved my pain. My first visit I was told if I didn’t get the CESI I could not be a patient.

I have 3 cervical bulging disc and osteoarthritis in all levels of joint and facet in my Cervical spine. I am unable to tolerate NSAIDs due to a bowel disease. I take Topomax which generally manages my occipital neuralgia. The above procedures are invasive and the last one bruised a nerve around my shoulder and the side of my neck. I was in pain for a month.

I am prescribed 3 10/325 hydrocodone to be taken every 8 hours as needed for pain. My last procedure kept me out of physical therapy.

How would payment work because if it’s based on getting paid for a great outcome or Improvement then how are the people that do not improve going to be treated BC there are a lot of chronic conditions other than just chronic pain that never improve? Strokes, MS, cerebral palsy, amputations, cancers of all kinds. The list goes on. Since the physician is paid on a Improvement or great outcome what would keep the physician from lying? Just like now with the EHR system doctors put in more CPT codes then they really did BC it’s easier payment system just to go down the line & this is straight from a physician saying this. Again this is working on a narrow thinking. Just like chronic pain people all become addicted BC they receive pain medication. Not the fact that there are people out there who just want to get high so they throw everyone under the bus. A narrow thinking. Life has variables all throughout Mankind’s history. There’s healthy not healthy. There’s death or life, theft or honesty, boastful or humble, rich or poor, medication use or abuse. Lies or truth. The only way to make sure about reasonable payment not based on greater outcome or Improvement is to have a camera with audio in the Physicians office where the patient & the physician get a copy along with Medicare or whatever insurance. Because documentation on paper can be lies. Which is written by one person the physician who will be in Tice for payment.

How about making more public hospitals eh?

Ellen Agard

I was too late to comment to the government. First, the language is utterly opaque. No idea what is intended. Second, before we link reimbursement to outcomes, we need to define outcomes. Chronic pain following interventions is not a good outcome. I had surgery. My joint still hurts. Does this mean I would have to change providers? Change strategies? Doctor shop? My doctor doesn’t get reimbursed?EmGyG

Sorry to keep adding stuff. I found what this articles talking about it’s called Center for healthcare Quality and payment reform. Why value-based payment isn’t working and how to fix it by Harold d. Miller
My question is it says doctors get paid for quality outcomes, what keeps the doctors from lying to Medicare & saying the patient is improving so they get paid? BC I read doctors notes before & say I was improving when I was actually going down hill bc they were overprescribing amitriptyline for migraines. I kept coming in & said I wasn’t doing better still had the migraines & every time I came in he just kept upping them to the point I was having chest palpitations felt my heart fluttering. I finally found a cardiologist handbook & it said that I was being over-medicated bc in the overmedicated symptoms I was having all those symptoms. Yet he wrote in every note I was improving & doing better so what keeps a physician from lying in medical notes for money no matter how it gets paid? It also said that the patient-centered payment system is no guarantee for Quality Care or a better outcome. And then it cost more to get this system started just like it did with electronic medical records. it also said this could mean higher cost for the patient & their insurance & for Medicare. Something doesn’t sound right to me?

I forgot to mention the Blackstone Group that is a Equity Firm that is buying Equity into doctors and buying out hospitals and multiple different Physicians offices. Team health is also involved with this company where they sue poor people if they don’t pay their bill. And unfortunately they put a percentage and then they keep increasing the percentage over certain amount of time to the point that the cost is more than what the bill originally was. Another great article called private Equity investments in physician practices and overuse by lown Institute

Thomas Wayne Kidd

What if anything is being done about our rights as Americans with Disabilities??? I have found that I actually don’t have any rights as soon as I walk through the clinic doors. Just one right, the threatening right to pay for mistreatment. People are truly insane to allow so-called doctors to cause more pain instead of trying to lessen the pain. It’s like going every 2 months and paying someone to beat us up and threaten us with being kicked out if we don’t continue to allow our torture. My religious beliefs are now under attack, wanting me to go to public pool and dress half naked and with other half naked people. I refuse to do these things against my conscience. I refuse to participate in their snake oil cures and witch doctor remedies. Where are the lawyers? They would be filing suit after suit if they were not in ka-hoots with those who are in power and conjured up this evil wicked plan to reduce the population and make much money while doing it. Meanwhile tons of Heroin and Fentynal continue to pour into the streets which we the suffering continue to be tortured. But what should we citizens of a nation that has legally murdered 80+ million babies since 1973.???? Wake up, Wake up. Our ship is sinking and life boats are not an option. Great God people are so many so blind???

This has to do with why doctors prescribe medications and devices for their patients.
Physicians payments Sunshine Act Healthfair’
Another website called propublica Dollars for Docs
It tells you how much money are doctors making off of medications or devices also propublica has a website to show you from CMS what’s your doctor rates in surgery whether he has had low , medium or High complications in surgery.
Also research what Kickbacks do doctors get for prescribing drugs

I know for a fact that doctors get lunches from pharmaceutical companies because I’ve seen them come in Physician’s office and asked what days do you have open. BC I asked the pharmaceutical rep outside what were they scheduling and they were open enough to say well we have luncheons to talk about drugs that the doctor may be interested in. I’ve also talked 2 a nurse say they feed is too well here I’m gaining weight.

I just recently lost a doctor for a refusal of trying a new medication. And this wasn’t the first time. I should have the right just say what goes in my body. I don’t flippantly say no , I do research on the medication. I’m a person who gets side effects easily. Medication and me do not work well together. I shouldn’t have to lose a physician over not taking a medication or use the medication and suffer through horrible side effects just to make a physician happy. It should be my decision.

Thomas Wayne Kidd

Ooh my god. More “hurry up and wait.” I went there, but, if I was well enough to read all of that I wouldn’t need no pain management. Which is exactly what I have now. My medicare is not paying 80% of my doctor visits. My last visit I was asked how I was doing, then the nurse practitioner went into a rant and poof a new diagnosis. “MEDICATION FIXATION.” I was as same as told that I didn’t matter, and if I die when snatched off of 30+ years of methadone, that we are not important and only government policy matters. My medicare Part B is now over $500.00 and I must pay as much as possible or get kicked out. They suggested that perhaps I can go to another clinic, but couldn’t give me any clue of where that would be. My American with Disabilities rights have been totally taken from me and millions of others. A return to actually treatment of our chronic pain and being allowed to participate in our treatment is what we need. Not another round of questions/ answers and comments which no one will read at all. This is getting more and more evil and wicked and it’s spilling over into National Pain Report. Insanity is quickly covering the nation as well as the rest of the world. Will anyone actually WAKE UP? My old physical body will no doubt die before this ever changes. Let’s face the raw truth, the Republicans and Democrats will continue fighting over border walls, impeachment and the Good Lord knows what else. And perhaps when the population is sufficiently thinned and all legal opioid medications are banned the Lord Jesus Christ will return for His few children left after the total destruction of this earth is accomplished. I grow so weary of the uncommpassionate uncaring and evil which has been plondered off on the innocent sick and dying. Soon death will much bepreferred to what is left of what used to be life. I know that I will be written off as a crazy deranged old man but as long as I have breath I will continue trying to get people to WAKE UP!

David Hickle

My comment about the health care system and government presidents system of the state of Ohio USA this nation America is the fact I’m leaving fleeing moving to the United kingdom in the summer

Lisa Hess

It doesn’t matter what we would say to HHS about our current predicaments with our doctors. Until the DEA stops sending letters threatening our pain management doctors, they will continue to taper or not prescribe at all. For three years after the CDC Guidelines appeared, my PM doctor and I have talked about how ridiculous the notion was. He kept me on the same MME until January 2019. Then all the news spread of the DEA raids to doctors and I the medications that I was stable on for 13 years were cut 3/4 so to reach the current 90MME. All that did for me was drastically lessen my quality of life. Now, he is waiting to hear if the CDC is going to take the MME from 90 to 50. Yesterday, he told me he will know in two weeks. Guess what happens then? He’s lowering me to 50MME. I had my annual spine MRIs done last week and yesterday was told I have to have emergency cervical spine surgery. This will be my sixth spine surgery (fourth cervical). Will I get any post operative pain management? The answer was no. Will my chronic pain be increased from this surgery because of the compromised position my spine has been for the past 10 years? The answer is a big fat YES! My doctor finally convinced me to try the morphine pump. Yesterday, I was ready to make the arrangements for the trial. It was to be a long shot because I need the medication to be bi-directional and that’s not how the pump is designed, but we were going to try. Now I’ll have to wait another three months. So, instead of trying to tell our doctors more of what they should or shouldn’t do, tell the DEA to go to the streets and leave medicine to our doctors to treat us like human beings.

Patti Maher

Time to make people accountable for their decisions. As a chronic pain sufferer, nothing makes me more angry than seeing people who take opiates for recreation ( let’s call it what it is) ~ and because they choose to overdo it the medical community takes away my pain meds or makes me jump thru proverbial hoops.
Let’s make it like alcohol, over 21 you can buy it over the counter, if you want to kill yourself, well then go ahead! At 21 you know right from wrong, how much to drink to get drunk without killing yourself..time for the same with pain meds. Quit punishing people with chronic pain because of these ignorant people. I just can’t..enough!


I don’t want to feel forced into a surgery of having a nerve stimulator implanted in me.

Barbara Campbell

Lower the amount of co-pays for the specialist doctors,,

Cindy too

What is CMP?

Other acronyms used above are explained, but not this one, which seems important, and Google isn’t helpful for this, at least not to me.

PLEASE answer this question.

Also, I’d love to comment to the govt, even on this short notice, but just dont’ understand what this is about. This column is too esoteric for me.

I have no idea what’s being proposed, or what CPP’s should want — what would benefit us — other than getting away from FFS and moving towards a more results-oriented payment system. But this is so broad and general, that I think the authors want more specific comments than just repeating this statement.

Maybe if I knew what CMP means, it would help. I dont’ know.

Kay Passmore

My doctors took me off Morphine & Vicodin after being prescribed this for 20 years. I was given a 30 day supply & then tuff, they didn’t give a flip. Even my old rheumatologist told me I could get a heroine on any street corner, cheap. Thx but that’s not what I had in mind. Our government doesn’t care, not sure anyone does. The reason the suicide rate is so high is that people can’t tolerate the pain & no one helps. For one week I wish an arrogant doctor would have to live with my degenerative pain, my rare diseases & be told take aspirin or Tylenol. I would love to watch them struggle. No booze to help the pain either. They don’t care, I have no respect for them. I hope they go through just a portion of what I deal with daily. It’s called “No Quality of Life”.

Kelli Cantrell

My life has gotten so bad. Not getting enough pain control and Dr has also taken anxiety dose down as well. Quality of life is terrible. I’m alive but not living. This has to stop. Drug addicts are still getting high . While chronic pain patients suffer. I’m starting to hate America. America doesn’t care about us.

Sandy M

I don’t understand what they are wanting from us at all.


The value of a product is determined by the consumer and the payor. Our government has recently awarded greater reimbursement for epidural steroid injections that are only effective 50% of the time and cause serious, disabling intractable pain and a lifetime of disability to patients who contract adhesive arachnoiditis when not injected correctly. It is estimated that the prevalence of adhesive arachnoiditis in the US is at least 2 million. Where is the value in incentivizing this procedure that the FDA has deemed is not appropriate to be used with steroids and the manufacturer of depo medrol have also deemed not to be used in the practice of epidural steroid injections? Other countries have an outright ban on the procedure. This incentivizing was done to combat the “opioid crisis”. The CDC’s own data has proven that this “crisis” is not, and has never been, related to overprescribing. The true crisis in volume of deaths is related to our young people using illicit, non-prescription fentanyl and it’s substrates, including carfentanil, and then overdosing. Chronic pain patients rarely become addicted. It is genetic with opiates and amounts to less than 1%. This has remained stable over the last 100 years. Chronic pain patients rarely overdose; however, when they do it it’s generally related to suicide from untreated pain these days. Unfortunately, science hasn’t given us anything that works as well for severe pain. Why are dangerous procedures being forced (coerced) on patients by pain management interventionalists in return for receiving a small amount of an opiate for severe pain? There have been thousands of patients on social media describing these forced procedures. Do ESI’s provide value? The answer would be no if the costs of lifelong intractable pain and suffering as well as the costs of disability to our country would be quantified. We are fighting the wrong war on prescription pain medicine, against good citizens who now live with incurable pain.


I would like to know what the DEA or the FBI or the federal government is going to do about people that are suffering and pain and they’re limiting opioids and benzos when they have been taking them for a long. Of time I have been in excruciating pain ever since 1979 and now because of the regulations and the lowering of my medication and some of them have been taken away I have been suffering is this a good quality of life hell no you tell me what a person supposed to do yes I depend on these medications to have a good quality of life and now it’s taking my quality-of-life down to about 50% or lower whereas before I was 100% I can do things and with my hands and now because everything is being lowered I cannot they took my migraine medicine away my Meniere’s medicine away lowered my patch and when am I supposed to do this country has gone to hell because of others that have overdosed on opioids and we have to suffer this is not right each person should be examined read their folders and their records and go one by one not go by the regulations of 90 ml mg that’s ridiculous you need to change the system go in and check everyone’s folder X-rays and MRIs CAT scans what we’ve been through I have Crohn’s disease Meniere’s disease RSD fibromyalgia neuropathy my office e osteoporosis osteoarthritis scoliosis migraines and I’m supposed to have a good quality of life when part of my medicine has been taken away you tell me what to do and each one of them are doing exactly that they’re controlling us this is not right every one of the DEA should go into their folders not by with just one doctor but all the doctors that they go to I’ve been to numerous doctors in the Air Force for 25 years and then came out and more doctors Sue Wilford Hall Medical Center and these doctors would not give me these medications if they were not needed I’ve had a bad time the last 45 years or so since 79 I would like a reply on this please sincerely Sheila G Gomez My email is she Gomez 2015 at gm