August 23, 2017

Update to new HCA opioid policy:

On August 23, 2017, the Health Care Authority sent a message through GovDelivery to providers explaining the new HCA opioid policy, which will go into effect for Medicaid on October 1, 2017. This communication included provisions for a 90 MED dose limit in most circumstances. We have decided to remove the 90 MED dose limit from the policy for now, for the reasons described below.

We did extensive review and discussion with stakeholders before releasing the policy. However, after broader release, it was brought to our attention that there were situations where the 90 MED limit could put a patient at risk of under-treatment. These include patients leaving the hospital after certain kinds of surgery or trauma, who may need short-term use of very high doses; and patients on chronic low-level opioids or opioid replacement therapy who have an acute pain problem and may need short-term escalation above 90 MED due to medication tolerance. The exception processes in the policy would not have worked well for these patients and their providers.

Creating a suitable process that takes these situations into account will take time. We want to make sure we arrive at the correct process, taking all possibilities into account. Rather than delay implementing the policy until this work can be done, we have decided to proceed with the other elements of the policy on October 1 as planned, but we have removed the 90 MED limit. This change also removes the need for peer-to-peer review.

We remain committed to addressing issues around dose escalation for opioids, and we believe 90 MED is an appropriate limit in most circumstances. We will work with stakeholders to explore the best process for achieving this.

We appreciate your engagement with this process. We believe this policy will be an important tool to address the opioid crisis and protect the safety of Washington Apple Health clients.

MED limit removed from HCA opioid policy