MSA News - The Centers for Medicare and Medicaid Services (CMS) Announce Changes to Hydrocodone Combination Product (HCP) Coverage

CMS’s announcement on November 17, 2014 of HCP coverage changes affects Workers Compensation Medicare Set Aside (WCMSA) proposals submitted on or after January 1, 2015.

In October 2014, the U.S. Drug Enforcement Administration rescheduled all hydrocodone combination products from C-III controlled substances to C-II controlled substances, which we reported in our article entitled “MSA News - The Drug Enforcement Administration (DEA) Reschedules Hydrocodone Combination Products (HCPs)”.

Normally, C-IIIs required a new prescription after five refills or after six months, whichever occurs first. C-IIs require new prescriptions at intervals no greater than 30 days. However, a doctor or other practitioner may issue up to three consecutive prescriptions in one visit, effectively authorizing the patient to receive up to a 90 day supply of a C-II drug.

For this reason, Medicare WCMSA guidelines will change on January 1, 2015 to allow 4 healthcare provider visits per year (90 day intervals) when C-II controlled substances are used continuously, unless healthcare provider visits are more frequent per substantiated medical documentation. Current “closed” WCMSA cases which are subsequently “reopened” after January 1, 2015 will also be subject to this new ruling.

Click here to learn more about the CMS WCMSA Controlled Substances Notice >>