In letters to the Centers for Medicare & Medicaid Services (CMS), the Association for Clinical Oncology (ASCO) commented on provisions that impact cancer care for Medicare beneficiaries in the 2024 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP) proposed rule, as well as in the 2024 Hospital Outpatient Prospective Payment System (HOPPS) proposal.

ASCO is committed to addressing and improving health equity, and the Association believes CMS is beginning to make critical changes that will foster physicians’ ability to address patients’ social determinants of health (SDOH) needs. ASCO supports CMS’ proposal to cover and reimburse Community Health Integration services, Principal Illness Navigation services, and SDOH risk assessments, all of which have the potential to improve patients’ clinical outcomes. ASCO supports these proposals in their efforts to ensure holistic care for people with cancer and success for clinicians and practices.

Despite the commendable policy proposals, ASCO is concerned about the current and future physician reimbursement landscapes if changes are not made to support physicians. If CMS moves forward with its proposed conversion factor rate and utilization assumptions of complex care add-on code G2211, physicians will face a 3.36% conversion factor decrease—and overall reimbursement cut—in 2024.

Offering care that is essential to successful outcomes for people with cancer should not come at the expense and devaluation of other necessary services. ASCO continues to urge CMS to work with Congress to implement positive updates to the Medicare provider Conversion Factor, fix the flawed budget neutral system, and end the annual cycle of decreased physician reimbursement, with the goal of supporting and sustaining beneficiary access to high-quality cancer care and physician practice health.

ASCO’s comments on the MPFS and QPP proposal, as well as the HOPPS proposal, offer additional recommendations on a variety of issues including telehealth, evaluation and management services, dental services, QPP performance thresholds, prior authorization, and buffer stocks of essential medicines. Highlights are outlined below.

Medicare Physician Fee Schedule

• Conversion Factor: ASCO urges CMS to work with Congress on reforms to the MPFS, including legislation that would provide an annual inflationary update based on the Medicare Economic Index.
• Specialty Impact: According to ASCO’s analysis, oncology practices would receive the following reimbursement decreases under to the 2024 MPFS proposal due to changes in Relative Value Units and the conversion factor cut:
  • Hematology/Oncology: 0.2% decrease to Medicare allowable rates
  • Radiation Oncology: 3.6% decrease to Medicare allowable rates
  • Gynecologic Oncology: 0.7% decrease to Medicare allowable rates
  • Surgical Oncology: 2.9% decrease to Medicare allowable rates
• Patient Navigation and Health Equity: To improve health equity and the overall care of individuals with cancer, ASCO recommends CMS finalize its proposal to cover and reimburse principal illness navigation, community health integration, and social determinants of health risk assessment services.
• Telehealth: ASCO supports CMS’ proposal to extend the originating site, geographic location, audio-only, and the higher, non-facility payment rate telehealth flexibilities through the end of 2024, as outlined in the Consolidated Appropriations Act.
• Evaluation and Management: ASCO supports implementation of the new evaluation and management code for complexity, G2211; however, the Association urges CMS to lower the utilization assumption to reduce the code's negative impact of the conversion factor.
• Dental Services: ASCO supports CMS’ proposal to cover dental services for Medicare beneficiaries prior to beginning chemotherapy or CAR-T, receiving bone-modifying agents, and for patients with head and neck cancers.

Quality Payment Program

• Merit-Based Incentive Payment System (MIPS) Performance Threshold: ASCO strongly opposes increasing the MIPS performance threshold from 75 points in performance year 2023 to 82 points in performance year 2024. CMS estimates that under this policy, approximately half of MIPS eligible clinicians would receive a negative payment adjustment (up to -9%) for the 2024 performance period. This policy would also further disadvantage small practices, as the agency estimates that 60% of such practices would receive a financial penalty.
• Qualifying Participant Determination: ASCO does not support CMS’ proposal to make qualifying participant (QP) determinations at the individual level alone. We recommend that CMS determine QP status at both the APM entity level and the individual level, and to designate the clinician as a qualifying participant based on qualification in either category.

Hospital Outpatient Prospective Payment System

• Prior Authorization: ASCO thanks CMS for not imposing prior authorization requirements on additional services in 2024. The Association urges CMS to review the current prior authorization program to assess its impact on utilization, patient access to care, and the administrative burden it generates.
• Buffer stock of essential medicines: ASCO supports CMS’ proposal to establish and maintain a buffer stock of essential medicines in a manner that does not promote hoarding or create additional shortages or supply chain challenges. The Association strongly urges CMS to adopt a similar policy to support patients receiving care in physician practices.

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