The American Medical Association (AMA) and American Society of Addiction Medicine (ASAM) have developed a concept for an opioid treatment alternative payment model (APM) which could - if accepted by CMS as an advanced APM - serve as a MIPS alternative.
The new model, the Patient-Centered Opioid Addiction Treatment (P-COAT) APM, “seeks to increase utilization of and access to medications for the treatment of opioid use disorder by providing the appropriate financial support to successfully treat patients and broaden the coordinated delivery of medical, psychological and social support services,” according to a joint statement from the organizations issued on April 16.
AMA and ASAM also released a paper detailing their proposal. The P-COAT APMs would engage not only addiction specialists, but also non-addiction-specialist providers with authority under the Drug Addiction Treatment Act of 2000 (DATA 2000) to dispense buprenorphine, as well as other clinical providers from nurses to social workers who would work together in Opioid Addiction Treatment Teams (OATTs).
The three payment models available to P-COAT APMs would be Payments for Medical Management by a DATA 2000 Practitioner, Payments for Medical Management by an Addiction Specialist, and Payments for Comprehensive Services from an Opioid Addiction Team. Providers in the first two models would be paid “using existing billing codes or other payment methods that support their services,” but the third would receive bundled payments “designed to cover all those services, and it would not bill for those services using current billing codes.”
The bundled payments would come as a one-time Initiation of Medication-Assisted Treatment (IMAT) payment to cover the first six months of treatment, and a lower monthly Maintenance of Medication-Assisted Treatment (MMAT) payment to “provide or coordinate the provision of ongoing outpatient medication, psychological treatment, and social services to a patient who has successfully initiated treatment for an OUD [opioid use disorder].” These payments would continue based on need and patient participation.
Higher amounts would be paid for patients “with more complex needs that require more intensive supervision and services,” and “add-on payments would be available for practitioners that use treatment and recovery support tools” such as remote patient monitoring for patients with chronic conditions.
There would also be performance-based payment adjustments on IMAT and MMAT payments, very like the ones used in the current Quality Payment Program (QPP), based on Initiation of Treatment and Utilization of Services measures to judge the APM’s care against benchmarks, e.g. “percentage of patients who filled and used the medications prescribed to initiate treatment” and “risk-adjusted average number of opioid-related emergency department visits per patient.”
AMA and ASAM are seeking practices and insurers to engage in a pilot program for P-COAT, usually the first step toward acceptance as an APM -- which is itself a step toward becoming an advanced APM, the QPP alternative to MIPS (Merit-based Incentive Payment System); interested parties may contact them here.