CMS Must Address Burden of Prior Authorization, Reimbursement for 340B Cuts, Rural Hospital Support

September 27, 2022

In comments to the Centers for Medicare & Medicaid Services (CMS) on the 2023 Hospital Outpatient Prospective Payment System (OPPS) proposed rule, the Association for Clinical Oncology (ASCO) continues to call for a final rule that supports patient access to high-quality, equitable cancer care and support for oncology providers. Highlights from ASCO’s comments include:

Prior Authorization

In the 2023 proposed rule, CMS is continuing to advance its Prior Authorization (PA) program in Medicare. Although proposed additions to the list of items or services requiring PA are not directly related to cancer care, ASCO’s comments continue to stress the burden of PA on physicians and the detrimental effects it has on patient care. ASCO did not support the CMS policy in 2020 to establish a PA process for certain outpatient department services, and the Association continues to strongly oppose CMS’ proposal to expand PA requirements in 2023. We urge the agency to review the current program to assess its impact on utilization, patient access to care, and the administrative burden it generates.


CMS proposed a continuation of its 2018 cut to 340B reimbursement, which resulted in the reimbursement rate going from average sales price (ASP) +6% to ASP -22.5% for separately paid drugs and biologicals acquired through the 340B drug pricing program. However, the Supreme Court struck the cut down, so the agency anticipates finalizing a reimbursement rate of ASP +6% for 340B drugs and biologicals in the 2023 final rule.

ASCO’s supports CMS’ intent to finalize a payment rate of average sales price (ASP) +6% for drugs in the 340B program, and we urge CMS to come to a swift decision and implementation timeline regarding reimbursement for payment cuts because of the ASP -22.5% policy from 2018-2022. Reimbursement remedies for some sites of service should not result in penalties for others.

Rural Providers

ASCO’s comments support efforts to improve cancer care access in rural/underserved areas by considering all covered outpatient department services as rural emergency hospital (REH) services. ASCO supports CMS’ proposal to pay REHs 105% of OPPS payments for services furnished to program beneficiaries, and to make a supplemental monthly facility payment for calendar year 2023. We urge CMS to provide these resources to REHs but not at the expense of other hospital outpatient services.

Additionally, the Association voiced its support for CMS’ proposal to exempt services furnished by excepted off-campus, provider-based departments of rural, sole community hospitals from site-neutral payment policies.

Read the full letter.

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