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Author: WorkCompAcademy

CWCI Says Medical Report Costs Fell by 30% Last Year

The average amount paid to a California workers’ compensation treating physician for a medical report fell more than 30 percent in the first quarter of 2014 as the state began to transition to a Resource-Based Relative Value Scale (RBRVS) fee schedule, though a CWCI analysis traces the decline to changes in how various evaluation and management (E/M) services are reimbursed rather than reductions in the fees assigned to the report codes.

California’s transition to an RBRVS fee schedule that began a year ago led to 2 changes affecting physician reporting: 1) consulting physician evaluation services are now billed using an initial visit code, and associated reports are no longer separately reimbursable unless requested by the DWC Administrative Director, the Appeals Board or a Qualified Medical Evaluator in the context of a med-legal evaluation; and 2) the reimbursement to the primary treating physician for medical records review outside the context of a face-to-face E/M service has been bundled into the face-to-face E/M service fee, and there is no longer a separate allowance for a prolonged service fee.

To monitor how physician reporting changed after these changes took effect, CWCI Senior Research Associate Stacy Jones compared data on medical reports for service dates from the first quarter of 2014, when the transition to the new schedule began, to corresponding data from the first quarters of 2011, 2012 and 2013, when the old fee schedule was still in effect. After determining the average amounts paid and the distribution of reports by the nature of the underlying E/M service (i.e., reports associated with initial visits, consultations, follow-up visits, prolonged services), Ms. Jones found that while the average amount paid for all physician reports fell more than 30 percent under the RBRVS fee schedule, the changes in the average reimbursements varied dramatically by type of report.

Comparing the mix of reports associated with the various E/M services revealed that after the rules changed under the new schedule, relatively inexpensive reports on follow-up visits increased from 78 percent to 86 percent of all physician reports, while the biggest declines were in consultation and prolonged service reports, which historically received the highest reimbursements. Consultation reports, which had represented 6 percent of physician reports under the old schedule, and prolonged service reports, which had accounted for 4 percent, both dwindled to less than 1 percent of all reports after the RBRVS schedule took effect. Thus, the initial results on physician reporting following adoption of the new schedule indicate that the change in the mix of reports has been the key factor in reducing the average amount paid for physician reports.

CWCI will continue to monitor the volume, distribution and reimbursement of physician reports in California workers’ comp as more developed data become available. In the meantime, the Institute has published a Research Update report, “Changes in Workers’ Compensation Physician Reporting Under California’s RBRVS Fee Schedule: Initial Results,” which provides additional details and graphics from the latest study. The Research Update report is available to CWCI members and subscribers in the Research section at www.cwci.org.

H-Wave Suit Against SCIF Claiming Blanket UR Denials Reinstated

The unpublished Court of Appeal decision in Electronic Waveform Lab v. EK Health Services addresses whether UR is an “official proceeding” within the meaning of Code of Civil Procedure section 425.16, subdivision (e)(2) (the anti-SLAPP statute [SLAPP is the abbreviation for strategic lawsuit against public participation]) and whether the trial court correctly resolved the motion to dismiss under that statute filed by defendant State Compensation Insurance Fund.

Waveform manufactures and sells an electrotherapy device, commonly known as an H-Wave device, which physicians may prescribe to assist in treating various muscular injuries. State Fund contracts with EK Health and “independent contractor individual physician reviewers” to provide UR services to workers covered by their employers’ workers’ compensation policies issued by State Fund. Waveform filed suit against EK Health, alleging that EK Health was “situated as a monopolistic ‘gate keeper’ to a significant and substantial market share of patients who are injured on the job.” Waveform further alleged that EK Health and the Reviewers conspired to defame Waveform and consistently denied the H-Wave device for treatment of individual patients, with the result that treating physicians asked Waveform to remove H-Wave equipment from doctors’ offices and physical therapy clinics. Waveform alleged that the conduct of all of the defendants violated the Cartwright Act (Bus. & Prof. Code, §§ 16720 et seq.) and that the acts of EK Health and of a subset of the Reviewers constituted intentional interference with prospective economic advantage and trade libel.

EK Health and the Reviewers filed a special motion to strike the complaint under section 425.16 (anti-SLAPP motion) which was denied. The denial of the EK Health motion was not appealed.

Waveform then filed a first amended complaint adding State Fund as a defendant. Waveform alleged that State Fund had implemented through EK Health a “blanket policy” to deny and reject physicians’ prescriptions for utilization of the H-Wave device in treatment of patients’ injures and that “[w]hile creating the appearance of reviewer independence, EK Health and the reviewers in fact complied with State Fund’s policy that all H-Wave requests be denied.” Waveform alleged, the policy “violates the independent medical decision-making that reviewers are required to engage in. . . .”

State Fund filed its own anti-SLAPP motion seeking to dismiss both causes of action alleged against it. The trial court ruled that State Fund had established that its actions arose from “official proceedings” as its actions constituted “statements made in connection with an issue under consideration in a legally-authorized official proceeding.” The trial court also concluded that plaintiff had not shown a probability of prevailing against State Fund at trial and for these reasons granted the State Funds anti-SLAPP motion and it was dismissed. The Court of Appeal reversed.

The parties contest whether UR is an “official proceeding authorized by law” as that term is used in section 425.16, subdivision (e)(2). State Fund argues that “official proceedings” include administrative agency actions involving review and investigation of grievances, and that the workers’ compensation UR system, which involves resolution of claims for medical treatment, should be similarly viewed. Waveform argues that the UR process is not quasi-judicial or part of a comprehensive statutory licensing scheme which is subject to judicial review by administrative mandate. The Court of Appeal ruled that it was not an official proceeding and distinguished UR from case law on arbitration proceedings by saying “UR review is medical rather than legal and informal rather than formal.” “For this reason alone, the trial court erred in concluding that UR is an “official proceeding” within the meaning of that term in section 425.16, subdivision (e)(2).”

The judgment dismissing State Fund from Waveform’s first amended complaint was reversed.

Authorities Say Elderly Care Industry “Rampant With Fraud”

A story published in ChicoER says that an Antioch businesswoman will serve 60 days in jail and pay restitution after pleading guilty to wage theft, tax fraud and a workers’ compensation violation in her operation of elderly care facilities in Antioch and Brentwood, the first conviction in an industry authorities say is “rampant” with fraud.

Florinda Yambao, 62, accepted the plea deal last week, according to the Contra Costa District Attorney’s Office. Yambao’s six Florin White Dove care homes in Antioch and Brentwood remain in operation, however her three-year probation term requires her to install proper payroll systems and undergo state audits, said prosecutor William Murphy. She is required to pay $453,000 in back wages and yet-to-be determined tax charges and state fines as part of her deal.

Nearly $72,000 was recovered from Yambao during a series of September raids on care homes throughout Contra Costa County, all accused of paying workers under the table and for as little as $4 an hour. In some cases, officials have said, caregivers in her employ worked 12 to 16 hours a day for $50 to $80 total.

After an article by the ChicoER on the searches, Murphy said his office, which has worked with state and federal officials in a yearlong investigation, was flooded with accusations against more homes. “We were inundated with similar problems in other homes in Contra Costa County,” Murphy said. “It appears to be rampant.”

The Contra Costa Employer Fraud Task Force is investigating the owners of nine other care homes that operate 40 facilities in the county. The investigation has uncovered a pattern of underground economy violations where these businesses increased their profits by avoiding taxes, insurance and fair wages, according to the Contra Costa DA’s office. The probe has also found many of the workers are mistreated, working long hours for less than minimum wage, living in substandard conditions, and being forced to care for patients during their time off, the task force said in a statement.

In addition to Yambao, police arrested Sara Abraham and Annette and Julio Sanchez of Abraham Rest Homes Inc. and Sanchez Abraham Corp. after a series of September raids on 19 residential care homes in Walnut Creek, Concord, Brentwood and Antioch. Authorities said about 60 workers were owed $2 million, and $624,000 in state fines against the companies would be split among the workers. Authorities said they were also investigating the owners of Scienn Hall Care homes in Brentwood, but no arrests were made.

While there were no allegations of mistreatment of patients at Yambao’s homes, state records showed that five facilities shown as “Floran Care Home” or “Floran White Dove Care Home” received as many as 19 citations in their inspections. “Ms. Yambao, as the owner and boss of these care facilities, was in a position of power over her employees,” District Attorney Mark Peterson said. “She used that position to exploit the workers and line her own pockets with the cash. It was pure greed.”

Study Identifies Factors Contributing to Back Pain Risk

Under SB 899, apportionment can now be based upon causation. Apportionment can be used to divide a specific injury case into two cases, the original specific injury, and then a continuous trauma case if continuous trauma played a causation role in the current medical problem. This strategy can take a life pension specific injury claim and reduce it to two smaller cases neither of which triggers a life pension. For this reason, it becomes significant to follow medical literature as elements of causation are developed in the medical literature. Here is a current example.

New research reveals the physical and psychosocial factors that significantly increase the risk of low back pain onset. In fact, according to the article in Science Daily, results published in Arthritis Care and Research, a journal of the American College of Rheumatology (ACR), show that being engaged in manual tasks involving awkward positions will increase the risk of low back pain by eight times. Those who are distracted during activities or fatigued also significantly increase their risk of acute low back pain.

At some point, nearly 10% of the world’s population experience back pain, which is the leading cause of disability according to the World Health Organization (WHO) Global Burden of Disease report (2010). WHO reports that low back pain has a greater impact on global health than malaria, diabetes, or lung cancer; yet little progress has been made to identify effective prevention strategies.

“Understanding which risk factors contribute to back pain and controlling exposure to these risks is an important first step in prevention,” explains Associate Professor Manuela Ferreira, Ph.D., with The George Institute for Global Health and Sydney Medical School at The University of Sydney in New South Wales, Australia. “Our study is the first to examine brief exposure to a range of modifiable triggers for an acute episode of low back pain.”

For this case-crossover study, researchers recruited 999 participants from 300 primary care clinics in Sydney, Australia, who had an acute low back pain episode between October 2011 and November 2012. Study subjects were asked to report exposure to 12 physical or psychosocial factors in the 96 hours prior to the onset of back pain.

The risk of a new episode of low back pain significantly increased due to a range of triggers, from an odds ratio of 2.7 for moderate to vigorous physical activity to 25.0 for distraction during an activity. Researchers found that age moderated the effect of exposure to heavy loads, with odds ratio for individuals 20, 40, or 60 years of age at 13.6, 6.0, and 2.7, respectively. A new finding not reported previously was that back pain risk was highest between 7:00 a.m. and noon.

“Understanding which modifiable risk factors lead to low back pain is an important step toward controlling a condition that affects so many worldwide,” concludes A/Prof Ferreira. “Our findings enhance knowledge of low back pain triggers and will assist the development of new prevention programs that can reduce suffering from this potentially disabling condition.”

The citation to this study is: Daniel Steffens, Manuela L Ferreira, Jane Latimer, Paulo H Ferreira, Bart W Koes, Fiona Blyth, Qiang Li, Christopher G Maher. What triggers an episode of acute low back pain? A case-crossover study. Arthritis Care Research, 2014; DOI: 10.1002/acr.22533

DWC Concludes Amendments to OMFS

The Division of Workers’ Compensation has adopted and filed an amendment to the official medical fee schedule (OMFS) with the Secretary of State. The amended regulation reiterates the applicable dates of fee schedule provisions that are declaratory of existing laws; addresses the operating disproportionate share hospital (DSH) adjustments to inpatient hospitals; addresses the inpatient hospital outlier payments for eligible transfer cases; updates inpatient hospital factors to 2014, and makes minor adjustments to various sections of the OMFS.

The regulation amends title 8, California Code of Regulations sections, and is effective March 5, 2015. The regulation can be found on the DWC website’s rulemaking page.

The DWC has also issued an administrative director (AD) order adjusting the inpatient hospital section of the OMFS to conform to changes in the 2015 Medicare payment system as required by Labor Code section 5307.1. The effective date of the changes is March 5, 2015. Although 2014 update factors were adopted in the OMFS rulemaking (discussed above) with the same effective date of March 5, 2015, the 2015 update factors adopted by this AD order should be used for dates of discharge on or after March 5, 2015.

Further information and adjustments to the inpatient hospital section of the OMFS can be found on the DWC website’s OMFS page.

2015 – The Year of the Health Care Hack

Security experts are warning healthcare and insurance companies that 2015 will be the “Year of the Healthcare Hack,” as cybercriminals are increasingly attracted to troves of personal information held by U.S. insurers and hospitals that command high prices on the underground market according to the story in Reuters Health.

Anthem Inc, the No. 2 U.S. health insurer, last week disclosed a massive breach of its database containing nearly 80 million records, prompting investigations by state and federal authorities. That hack followed a breach last year at hospital operator Community Health Systems, which compromised some 4.5 million records.

“People feel that this will be the year of medical industry breaches,” said Dave Kennedy, chief executive of TrustedSEC LLC. In the past decade, cybercriminals focused their efforts on attacking banks and retailers to steal financial data including online banking credentials and payment card numbers. But as those companies boost security, using stolen credit card numbers has become more difficult. Their prices on criminal exchanges have also dropped, prompting hackers to turn to the less-secure medical sector, just as the amount of digital healthcare data is growing dramatically, Kennedy said.

Stolen healthcare data can be used to fraudulently obtain medical services and prescriptions as well as to commit identity theft and other financial crimes, according to security experts. Criminals can also use stolen data to build more convincing profiles of users, boosting the success of scams. “All of these factors are making healthcare information more attractive to criminals,” said Rob Sadowski, marketing director at RSA, the security division of EMC Corp.

RSA Executive Chairman Art Coviello recently wrote in a letter to customers that he expected well-organized cybercriminals to turn their attention to stealing personal information from healthcare providers. “A name, address, social and a medical identity … That’s incredibly easy to monetize fairly quickly,” said Bob Gregg, CEO of ID Experts, which sells identity protection software and services. Identities can sell for $20 apiece, or more, he said. Insurers, medical equipment makers and other companies say they have been preparing for breaches after seeing the waves of attacks on other industries.

Cigna Corp has looked to financial and defense companies for best practices, including hiring hackers to break into its systems, said Chief Executive David Cordani. Attempts to break into corporate systems to probe for information are a constant, he said in an interview.

St Jude Medical Inc CEO Daniel Starks said the company increased investment in cybersecurity significantly over the last few years, to protect both patient data and the medical devices it manufactures. “You may see from time to time law enforcement briefings on nation-based (intellectual property) issues, espionage,” he said. “Those are things that we take very seriously and have been briefed on and that we work to guard against.”

The insurers UnitedHealth Group Inc and Aetna Inc have warned investors about the risks of cyber crime in their annual reports since 2011. UnitedHealth has said the costs to eliminate or address the threats could be significant and that remediation may not be successful, resulting in lost customers. In response to the Anthem attack, UnitedHealth spokesman Tyler Mason said in an emailed statement: “We are in close contact with our peers in … the industry cybersecurity organization, and are monitoring our systems and the situation closely.”

Aetna has cited the automated attempts to gain access to public-facing networks, denial of service attacks that seek to disrupt websites, attempted virus infections, phishing and efforts to infect websites with malicious content. Aetna spokeswoman Cynthia Michener said in a statement: “We closely follow the technical details of every breach that’s reported to look for opportunities to continually improve our own IT security program and the health sector’s information protection practices broadly.”

Advanced Age Does Not Rule Out Spinal Surgery

As the number of Americans age 80 and older continues to rise, so does the percentage of patients with acute spinal conditions. A new study appearing in the Journal of Bone and Joint Surgery (JBJS) found significant benefit from surgical treatment for lumbar spinal stenosis with and without degenerative spondylolisthesis–debilitating spinal conditions causing leg and back pain, numbness and weakness–and no higher overall complication rate and no higher mortality for patients age 80 and older when compared to patients younger than age 80.

Between 2000 and 2010 the U.S. population age 80 and older increased 22 percent to 11.2 million, and approximately 47 percent of Americans age 60 and older have spinal stenosis, a narrowing of the spinal canal due to the wear and tear associated with aging.

In this study, researchers reviewed Spine Patient Outcomes Research Trial (SPORT) data for 105 patients, age 80 and older, and 1,130 patients younger than age 80 with lumbar stenosis alone or combined with degenerative spondylolisthesis. Patient clinical characteristics, including age, sex, ethnicity, college and work status, body mass index (BMI), smoking, comorbidities, level of back and leg pain, self-assessment of general health and treatment preference, were reviewed at baseline. Levels of pain, assessment of general health, complications, the need for revision surgery, and mortality were measured postoperatively for up to four years.

“This study demonstrates that surgery for the treatment of lumbar stenosis and degenerative spondylolisthesis provides significant benefit compared to nonoperative treatment in those patients over the age of 80,” said lead study author Jeffrey A. Rihn, MD, an orthopaedic surgeon at the Rothman Institute and associate professor at Thomas Jefferson University Hospital in Philadelphia, Pa. “Patients in this age group had significant improvement in their function after surgery and complication rates comparable to the younger demographic. Based on the results of this study, surgery should be considered a viable treatment option for these lumbar conditions in patients older than age 80. Future studies are needed to better assess the cost-effectiveness of surgery in this patient population.”

Reserving claim files for life time medical awards will be more accurate if studies such as this one are taken into account.

Supreme Court to Rule on Medication Related Death Case

Arguments will be presented to the California Supreme Court next month in the case of an injured worker whose death from a prescription drug overdose was ruled noncompensable by the 4th District Court of Appeal in December 2013. The high court is scheduled to hear arguments in South Coast Framing v. Workers’ Compensation Appeals Board on March 3 in San Francisco. The court agreed last March to consider the case.

Brandon Clark, a South Coast employee, suffered back, head, neck and chest injuries when he fell off a roof while working for South Coast in 2008. His workers comp doctor prescribed an antidepressant, Vicodin and Neurontin, a drug used to treat neuropathic pain. Mr. Clark also was prescribed Xanax and Ambien by his personal physician in January 2009 for anxiety and sleep problems. He died the following July allegedly from the combined effects of the antidepressant, Neurontin, Xanax, Ambien and associated early pneumonia.

Mr. Clark’s wife and children filed for workers comp death benefits, contending that his death was a result of his work injury and related medications. She supported her claim with the report of Dr. Bressler who concluded that “[Brandon’s] death was secondary to an accidental overdose.” In reaching this conclusion, Dr. Bressler stated, “[t]he specific combination of medicines [Brandon] was on, which included Xanax, Ambien, Flexeril, Neurontin, amitriptyline, and hydrocodone, all separately and in combination had the capacity to induce respiratory depression, and even respiratory arrest.” Thus there was a mixed cause of both industrial and non-industrially prescribed medications. However the agreed medical examiner, Dr. Thomas C. Bruff, had a more detailed analysis of the interaction of the industrial and non-industrial drugs and came to the opposite conclusion.

A workers’ compensation judge concluded that Brandon Clark died as a result of medications he took after suffering an industrial injury. South Coast and its insurance carrier, Redwood Fire and Casualty Company administered by Berkshire Hathaway Homestate Companies petitioned for writ of review after the Workers’ Compensation Appeals Board denied reconsideration of the WCJ’s decision in favor of Brandon’s wife and children.

The Court of Appeal in the unpublished case of South Coast Framing v WCAB (Clark) concluded that the Board erred in denying reconsideration because the WCJ’s decision was not supported by substantial evidence. A physician’s report and testimony must demonstrate his opinion is based on “reasonable medical probability.”

The dispute will now be resolved by the California Supreme Court after oral arguments are heard next month.

Patriot National Announces New Acquisitions

Patriot National, Inc. announced the acquisitions of Phoenix Risk Management Insurance Services, Inc., a managing general agent (MGA) headquartered in Roseville, California, and DecisionUR, a software company offering sophisticated and effective utilization review solutions in the workers’ compensation industry. Material terms of the transactions were disclosed in a Form 8-K. The Company agreed to acquire substantially all of the assets of Phoenix for $1,099,000 in cash plus a performance-based cash earn-out of up to $3,000,000. Pursuant to the Acquisition Agreement, Phoenix will be entitled to an annual earn-out payment of up to $1,000,000 for the next three years subject to reduction on a pro-rata basis if the level of premium earned within the first year does not meet certain targets. The Company did not assume any material liabilities. The transaction closed on February 4, 2015.

“At Patriot we continuously look for opportunities to add complementary operations and innovative solutions to increase our reach and efficiency as a premier service provider in the insurance industry. With the acquisitions of Phoenix Risk Management and DecisionUR, we are executing our strategy to bolster our already strong franchise,” said Steven Mariano, Chief Executive Officer of Patriot National. “Phoenix’s well-established relationships with clients and carriers provide us with valuable contracts and access to new markets, and DecisionUR enhances the robust suite of services offered by Patriot Technology Solutions, which recently changed its name from Carrier and Technology Solutions, Inc. We anticipate that both of these transactions will be immediately accretive to EBITDA.”

Phoenix Risk Management Insurance Services, Inc. is an MGA that has served the California workers’ compensation industry for more than 36 years by offering niche market specialty insurance products and risk management tools.

DecisionUR’s software provides a cost-efficient way to conduct workers’ compensation utilization reviews by reducing the time to approve, modify, delay, defer or deny treatment requests. To further expedite decision-making, the software includes an automatic approval feature as well as custom protocols provided by clients to determine medical necessity. In addition, the technology allows clients to customize protocols based on their experience and document their statistical results. These custom protocols can interface with outside claims systems, bill review platforms and medical case management software programs.

Judith Haddad, EVP, Chief Information and Technology Officer of Patriot National, added, “With DecisionUR, we have acquired one of the most sophisticated, state-of-the art technology products in the marketplace today, and this gives our managed care operation an in-house tool that enhances its ability to control claim costs. This is another example of applying technology solutions to better serve policyholders in returning injured workers to their jobs.”

Patriot National is a national provider of comprehensive outsourcing solutions within the workers’ compensation marketplace for insurance companies, employers, local governments and reinsurance captives. Patriot National provides general agency services, specialty underwriting and policyholder services and claims administration services to its insurance carrier clients and other clients. Patriot National is headquartered in Fort Lauderdale, Florida with seven regional offices around the country.

Administrators Take Aim at Off-Label Meds

Medications such as Abilify and Actiq are being used off-label to treat injured workers, prompting the workers comp sector to focus on curbing inappropriate prescribing that may be pricey and dangerous. Research shows that about one in five of all prescriptions are written for off-label use, or uses outside those approved by the U.S. Food and Drug Administration. According to the article in Business Insurance, experts say the practice has popped up in workers comp with drugs such as Abilify, an anti-psychotic that’s FDA-approved as an add-on treatment for adults with depression, but inappropriately used as a lone treatment of injured workers’ depression or anxiety.

“We’re starting to see more Abilify being added to problematic claims, and Abilify really doesn’t have a place in work comp,” said Brian Carpenter, Atlanta-based senior vice president of pharmacy product development and clinical management for Healthcare Solutions. “It’s a very expensive medication.” About $6.5 billion was spent on Abilify in the United States in 2013, according to the IMS Institute for Healthcare Informatics. “Certainly because of the cost and the fact that … we believe there are other drugs that are therapeutically effective to do what it does, we would certainly try to have a conversation with a physician to not use the drug to treat an injured worker”, said Rita Wilson, Delray Beach, Florida-based CEO of Tower MSA Partners L.L.C., a Medicare secondary payer compliance company.

The impact of off-label drugs is difficult to quantify in workers comp since it’s not always clear why a medication is prescribed, said Brigette Nelson, Cave Creek, Arizona-based senior vice president of workers compensation clinical management at St. Louis-based pharmacy benefit manager Express Scripts Inc. However, sources said off-label use in comp is seen primarily in pain management.

Opioids make up a large percentage of off-label prescriptions, said Michael Gavin, Duluth, Georgia-based president of medical cost management company PRIUM. “It has serious implications for injured worker health because the FDA is signaling to the physician community that these drugs should be used in really limited circumstances, and yet we see our work comp payer community spending $1.5 billion a year on them,” Mr. Gavin said. It’s important for PBMs and third-party administrators to be familiar with medications commonly prescribed off-label so they can appropriately flag and monitor claims, sources said.

State rules also can come into play. For example, a recent update proposed for the California Medical Treatment Utilization Schedule could limit off-label use by requiring physicians to prove with a study or alternate guideline that that treatment contrary to the state’s schedule is appropriate. Off-label prescribing becomes a problem when physicians prescribe potentially dangerous and expensive drugs, such as “Actiq instead of Vicodin or Norco,” said David Cooper, director of orthopedic surgery at The Knee Center in Wilkes-Barre, Pennsylvania. Actiq, which is FDA-approved for breakthrough, chronic cancer pain, is a drug that sources agree has no place in workers comp. “We’ve seen (Actiq) used in workers compensation for nonspecific low back pain,” Mr. Gavin said. “That’s incredibly damaging. That’s a very powerful narcotic.” He said use of Actiq has declined in recent years as “we’ve gotten smarter as a payer community.”

One of the most important things a TPA can do is partner with the right doctors to avoid off-labeling from the onset, said Debbie Michel, Chicago-based president of TPA Helmsman Management Services L.L.C. And in states that allow it, conducting utilization reviews is considered a best practice to decide whether off-label use is appropriate, experts said.