John Plahovinsak
On September 26, 2023, the Department of Veterans Affairs (VA) Office of Inspector General (OIG) issued a Report concerning the Non-VA Healthcare Providers who prescribe Opioids to disabled veterans.
The Executive Summary of the Report recommended that the VA’s Oversight of the Non-VA’s Healthcare Providers should be strengthened when they provide opioids to disabled veterans.
The MISSION Act of 2018 extended healthcare for eligible disabled veterans into the community and addresses concerns about the effect of the opioid epidemic on veterans. The Act also consolidated VA Community Care Programs.
In 2016, the Centers for Disease Control and Prevention (CDC) reported that the disabled veterans have a greater risk of opioid overdose leading to death when compared to the general population. Most fatal dose overdoses were associated with patients who received opioid prescriptions from multiple healthcare providers.
During Fiscal Year (FY) 2021, the VA issued over 3.2 million opioid prescriptions to approximately 577,000 veterans. This included over 146,000 opioid prescriptions issued by non-VA healthcare providers through the VA’s Community Care Program to approximately 48,100 disabled veterans.
The MISSION Act of 2018 required that the VA Secretary ensures that all covered healthcare providers must certify and follow the VA/DoD Clinical Practice Guideline for Opioid Therapy for Chronic Pain for prescribing opioids. This is known as the Opioid Safety Initiative (OSI) guidelines.
The VA’s Office of Integrated Veteran Care (IVC) is the program office responsible for overseeing the implementation of the MISSION Act guidelines requirements.
The VA has contracts with two (2) third party administrators to manage non-VA Providers in the VA’s Community Care Network (CCN).
The IVC contracting officer representatives coordinate with VA contracting officers to ensure compliance with the OSI guidelines.
According to the OSI guidelines, from the 1990s until 2008, the proportion of pain visits where patients received opioids significantly increased, as did the number of opioid-related deaths and substance abuse disorder treatment admissions.
From 2008 until 2018, the annual percentage of filled opioid prescriptions significantly decreased. This decline might be attributed, in part to the implementation of opioid-prescribing guidelines.
The VA Office of Inspector General (OIG) initiated this audit to determine whether VA, as required by the MISSION Act, ensured non-VA providers were provided a copy of the OSI guidelines and certified that they have reviewed them.
The OIG Audit Team found although the VA is responsible for MISSION Act requirements compliance, the IVC did not provide adequate oversight of the third-party administrators. Specifically, with respect to ensuring that non-VA providers received and certified that they reviewed the OSI guidelines.
The OIG Audit Team estimated that about 14,700 of approximately 18,200 non-VA providers in the CCN, who prescribed opioids to veterans in FY 2021, have not completed VA’s OSI training module and have not certified they have received and reviewed the OSI guidelines.
Based upon the data provided by the OIG Audit Team, the OIG made the following recommendations to the VA Under Secretary of Health:
First, to clarify the roles of the Office of IVC and third-party administrators to ensure that non-VA providers received and certified that they have reviewed the OSI guidelines contained in the MISSION Act of 2018.
Second, to ensure the Office of Integrated Veteran Care (IVC) strengthens controls to monitor the third-party administrators to ensure non-VA providers’ completion of the OSI training module.
Third, to ensure the Office of IVC strengthens controls to monitor the third-party administrators to ensure non-VA providers’ completion of required prescription drug monitoring program (PDMP) queries.
My Opinion: Over 48,000 disabled veterans are currently receiving opioid drug prescriptions from non-VA healthcare providers. This is being paid by the VA, under the auspices of the VA’s Community Care Program, which was established with the MISSION Act of 2018.
The VA’s Community Care Program has contracted with two (2) third party administrators. These two (2) third party administrators were selected to provide oversight to non-VA providers who are issuing opioid prescriptions to our disabled veterans.
According to a recent OIG Audit, neither of these two (2) administering agencies are providing the proper and required oversight in two specific areas. First, is the compliance with the OSI specified guidelines and second is the completion of a review of the OSI training module.
Currently, 14,700 (out of an estimated 18,200) non-VA providers are not in compliance and therefore not certified to issue opioid prescriptions to our disabled veterans.
The VA should take immediate action to correct this situation. The lives and fates of over 48,000 disabled veterans are in the hands of 14,700 non-VA providers who are not certified to issue opioid drug prescriptions.
BioSketch: John Plahovinsak is a retired 32-year Army veteran, who served from 1967 to 1999. He is a life member of the Disabled American Veterans (DA) and serves as the DAV Department of Ohio Hospital Chairman and Adjutant of Chapter #63 (Clermont County). He can be reached at: plahovinsak@msn.com.