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NCCAOM Action Alert:
Comments on HHS Pain Management Task Force Draft Report

There is a new opportunity to express support for expanded access to and usage of acupuncture for pain management through the federal government. The Department of Health and Human Services (HHS) formed the Pain Management Best Practices Inter-Agency Task Force, whose mission is to determine whether gaps or inconsistencies in acute and chronic pain management exist, and to propose recommendations to address those gaps. The Task Force has recently released their draft report on their work so far, which can be found here.

This report is currently open for public comment, and the final report will be submitted to Congress later in the year to serve as a basis for future work in improving and modernizing pain management in the U.S. The NCCAOM Advocacy Committee has submitted a detailed comment letter providing additional support and focus on targeted provisions in the report, and we need your input to provide an expanded voice for our NCCAOM National Board-Certified Acupuncturists™.

Comments are due to HHS by Monday, April 1st, 2019. Below is a brief summary of the provisions in the report and a suggested outline for public comments. In addition to soliciting feedback from our Diplomates, we also encourage you to ask your patients to submit supportive comments, and we have included guidance on developing patient comments as well.

Report Overview:

The draft report has a solid base to support complementary, non-pharmacological pain management as well as specific details on the practice of acupuncture for treating pain. The report focuses on the importance of a multidisciplinary approach to chronic pain and individualized, patient-centered care, as well as emphasizing a biopsychosocial model of care. The report calls for expanded access to a variety of treatment modalities, especially complementary and integrative health, including acupuncture, massage, yoga, and tai chi.

The report recommends that non-pharmacological pain management options be prioritized for both chronic and acute pain, and it calls for the federal government and private payors to reevaluate and redesign payment systems in order to encourage expanded use of these treatments. Additionally, the Pain Management Best Practices Inter-Agency Task Force recognizes the importance of improved patient and provider education around pain management and non-opioid avenues for treating pain. Finally, the report highlights the importance of investing in additional research into the value of non-opioid treatments, especially complementary and integrative health, and into the practical integration of these treatments into the standard care delivery system.

Overall, the draft report will be very beneficial for the acupuncture community, as it represents a major push towards improving access to complementary and integrative health, and we hope that the report will be a stepping stone to improving coverage, reimbursement, research, and education around acupuncture for pain management.

What We Need From You:

The draft report is promising but will certainly not be the end of our work to promote acupuncture services. Right now, we need our Diplomates to weigh in on the draft report and let HHS know that they should continue to prioritize acupuncture and complementary and integrative health as they continue to address the opioid crisis. By sharing widespread support for the report’s provisions on acupuncture, you can help amplify the voice of our community and advocate for our profession, our practice, and our patients.

How To Submit Comments:

  • Review our outlines below and prepare to share additional information about your practice and how acupuncture helps your patients.
  • Visit http://www.regulations.gov and search for Docket Number: HHS-OS-2018-0027 (or follow this direct link).
  • Click the button that says, “Comment Now!” and input your feedback in the designated text box. (Note: our outlines below are meant to be a guide – feel free to use your own words.)
  • Submit your comments by the end of the day (11:59pm ET)  on April 1, 2019.
  • If you have any questions about how to submit comments, feel free to reach out to our Government Relations Department at [email protected].

Draft Comments for Providers:

  • As an NCCAOM-Board Certified Acupuncturist practicing in (Your City, State Here), I am pleased with the Task Force’s recommendations regarding acupuncture and integrative health.
  • Expanding access to acupuncture and other non-pharmacological pain treatments is essential for addressing the opioid crisis, and I appreciate the work the Task Force has done to raise awareness of these issues.
  • (Provide some background information on the type of patients you treat and how acupuncture helps them manage their pain. Be sure not to include personally identifiable information!)
  • (Add any additional information about the benefits your patients receive from acupuncture and the barriers that they may face in accessing your services.)
  • I agree with the Task Force’s recommendation that the federal government and private payors prioritize non-opioid, non-pharmacological pain management options. It is essential not only to recommend use of these treatments, but to improve coverage and reimbursement policies so that more patients are able to access treatments such as acupuncture.
  • It is important the federal government also promote education for providers and patients around non-pharmacological treatment options and the ways in which they can benefit from using these services.
  • Fully integrating acupuncture and other complementary and integrative treatments into the healthcare system will go a long way towards improving pain management in the U.S. and helping reduce our reliance on harmful opioids. This report is an important step towards developing a truly patient-centered, multidisciplinary approach to treating chronic and acute pain.

Draft Comments for Patients:

(Feel free to pass this information along to your patients and encourage them to submit comments on the draft report as well.)

  • I am a patient who receives acupuncture for pain management (and any other conditions/benefits that the patient receives) and I support the Task Force’s work to expand access to this treatment.
  • Expanding access to acupuncture and other non-pharmacological pain treatments is essential for addressing the opioid crisis, and I appreciate the work the Task Force has done to raise awareness of these issues.
  • (Provide any background on how acupuncture has helped you manage your pain, and any barriers you have faced in receiving this treatment – be sure not to include any personally identifiable information).
  • I agree with the Task Force’s recommendation that the federal government and private payors prioritize non-opioid, non-pharmacological pain management options. It is essential not only to recommend use of these treatments, but to improve coverage and reimbursement policies so that more patients are able to access treatments such as acupuncture.