The Colorado Medical Society has developed a fact sheet on the 90-day grace period. Authorized under the Affordable Care Act, the grace period allows for continuity of care in the case that patients miss health insurance premium payments but could put doctors on the hook for collecting payments from patients for past services. The key to protecting your practice is checking the patient's eligibility status prior to services being provided so that financial arrangements can be made in advance of potential problems later related to unpaid patient premiums.

> Click here to access the fact sheet

Earlier this year the Colorado Division of Insurance (DOI) issued proposed regulations to establish the requirements for the grace period when the policyholder is delinquent in the payment of monthly premiums. CMS and 10 other organizations submitted comments to strengthen the timing of the notification of physician practices and details required to be included in the notice.

While Insurance Commissioner Marguerite Salazar concluded that the DOI does not have the authority under current statute to incorporate the changes requested, she did issue a bulletin, B-4.77, to carriers in August that provides additional direction. CMS is pleased to report that many of the suggestions we made were accepted concerning what information is reported about a patient's eligibility status within the 90-day grace period and when physicians are alerted. The bulletin also clarifies the relationship between the grace period and the existing statute on eligibility verification.

We would like to thank Commissioner Salazar for taking the concerns of physicians and other providers into consideration. The bulletin will go a long way to ensuring that physicians and others receive consistent and timely information from carriers concerning their patients' eligibility status.

> Click here to access bulletin B-4.77

Plus, it's not too late to register for Annual Meeting

REGISTRATION: Click here to register online and view the meeting agenda. Registration closes Tuesday, Sept. 16. Questions? Contact Dianna Mellott-Yost at (720) 858-6321 or [email protected].

HOTEL: The Vail Cascade Resort has a limited number of rooms available at the preferred rate. Call the hotel for availability at 800-420-2424 and be sure to mention that you are with the Colorado Medical Society to receive the group rate. 

RESOLUTIONS AND BOARD ACTION ITEMS: All members are encouraged to view the resolutions and Board action items that will be considered by the House of Delegates and provide comments online. Comments must be submitted by close-of-business tomorrow, Friday, Sept. 12. Click here to view the resolutions and board action items. 

Last month, the DEA published in the Federal Register the final rule to transfer hydrocodone combination products (HCPs) from schedule III to schedule II. This rule takes effect Oct. 6, 2014. HCPs have been controlled in schedule III since enactment of the Controlled Substances Act in 1971. HCPs are the most frequently prescribed opioid in the United States: Nearly 137 million prescriptions for HCPs were dispensed in 2013.

> Click here to view the final rule for details on the regulatory requirements and various compliance dates.

The DEA has attempted to alleviate any burdens upon registrants caused by a 45-day effective date. For example, the DEA modified quota requirements to allow repackaging/relabeling of HCPs without a quota until Dec. 8, 2014. The department is also permitting legitimate HCP prescriptions issued before Oct. 6, 2014 to be refilled until April 8, 2015, if the prescription authorizes refills.

However, the AMA reports that due to state laws, insurance limitations, and some pharmacy processes, some health insurers and pharmacies may not honor refills on or after Oct. 6, 2014. Therefore, prescribers should be prepared to provide new hard copy or electronic prescriptions for patients beginning on Oct. 6, 2014, rather than have patients use what would have been existing refills. Click here for an AMA information sheet.

The Notice of Proposed Rulemaking (NPRM), Final Rule, and its supporting documents (i.e., medical and scientific evaluations, and economic impact analysis) may be viewed online at www.regulations.gov, Docket No. DEA-389, or on the DEA website at www.deadiversion.usdoj.gov.

On July 11, 2014, the Colorado Medical Society and the Colorado Prescription Drug Abuse Prevention Program of Peer Assistance Services presented "Clinical Challenges in Opioid Prescribing." A summary of the program is now available. Click here to access this summary.

Attendees learned how to identify patients who may be susceptible to prescription opioid misuse or abuse, recognize signs and symptoms of potential misuse and/or addictive behaviors, and provide appropriate opioid pain management while minimizing the risk of potential misuse or abuse.