APCM Compliance & Audit Checklist for Pain Management

Confirm patient has two or more chronic conditions, such as failed back surgery syndrome and depression, expected to last 12 months.

Document patient agreement for APCM services, including cost-sharing responsibilities and 24/7 access availability in the EHR.

Flag patients on high-dose Morphine Milligram Equivalents (MME) for prioritized monthly monitoring and pharmacist coordination.

Perform and document a baseline functional assessment using validated tools like the Oswestry Disability Index or PEG scale.

Utilize AI voice agents to explain APCM benefits to eligible patients and capture structured consent data for the clinical team.

Document that the state Prescription Drug Monitoring Program was checked prior to every monthly opioid refill request.

Record results of random or scheduled pill counts to ensure strict adherence to the prescribed pain management regimen.

Ensure recent Urine Drug Screen results are linked to the APCM monthly summary to prove ongoing medical necessity and safety.

Log any instances of early refill requests, lost prescriptions, or multiple pharmacy use as part of the patient risk profile.

Use automated AI systems to screen refill requests against the current care plan before routing to the provider for approval.

Document non-pharmacologic interventions such as physical therapy, CBT, or acupuncture within the electronic care plan.

Log outcomes and pain score changes following epidural steroid injections or nerve blocks to justify ongoing interventional care.

Document communication with orthopedic surgeons, neurologists, or psychologists involved in the multimodal pain care team.

Perform a full review of all medications, including OTC anti-inflammatories, to prevent adverse drug-drug interactions.

Establish specific, measurable goals such as 'walking 20 minutes daily' rather than just general pain reduction targets.

Ensure clinical staff or AI-integrated systems track the exact minutes spent on non-face-to-face care coordination activities.

Record monthly VAS or numerical rating scale scores to demonstrate the clinical effectiveness of the current treatment plan.

Systematically screen for opioid-induced constipation, sedation, or other common side effects during monthly check-ins.

Use AI to automatically generate structured clinical notes from monthly check-ins for direct insertion into the patient EHR.

Document the specific mechanism by which patients can reach a clinician after hours for acute pain flares or medication issues.