In a letter to the Centers for Medicare & Medicaid Services (CMS), the Association for Clinical Oncology (ASCO) comments on provisions in the 2023 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP) proposed rule that would impact cancer care for Medicare beneficiaries.

Medicare providers are facing significant reimbursement cuts starting January 1, 2023. The proposed cut to the Medicare physician conversion factor of approximately 4.5% would be compounded by the 2% sequestration cut that went back into effect on July 1, 2022, and a 4% pay-as-you-go (PAYGO) cut triggered by passage of the American Rescue Plan that is scheduled to begin on January 1.

ASCO is very concerned that these cuts threaten patient access to cancer care by jeopardizing the financial stability of many oncology practices. Practices, hospitals, and other stakeholders continue to face ongoing uncertainty about pandemic recovery, historically high inflation, staffing shortages, and growing administrative burdens.

In addition to addressing the pending 2023 Medicare cuts, ASCO’s extensive comments offer recommendations on a wide variety of issues including telehealth, evaluation and management (E/M) services, expanded colorectal cancer screening coverage, and the Advancing Cancer Care MIPS Value Pathway (MVP) in the Quality Payment Program (QPP). Highlights include:

Reimbursement Impact on Cancer Care

• ASCO strongly urges CMS to work with Congress to address the substantial cuts to Medicare reimbursement slated for 2023.
• ASCO urges CMS to work with Congress to implement a Medicare physician conversion factor increase to offset appropriate increases to E/M services and to protect Medicare beneficiary access to care and the viability of community oncology practices.

Evaluation and Management Visits

• ASCO supports the adoption of the American Medical Association’s (AMA) CPT Editorial Panel’s new code definitions and the AMA RUC’s recommendations for work relative value units and practice expense inputs that parallel the changes made in 2021 to office and E/M services.
• CMS should allow physicians or advanced practice providers to bill split or shared E/M visits based on either time or medical decision-making to mitigate the negative impact that the time-only option will likely have on patient care.

Payment for Medicare Telehealth Services

• ASCO supports CMS’ proposal to extend the originating site, geographic location, audio-only, and telehealth service list flexibilities for 151 days after the end of the COVID-19 public health emergency (PHE).
• ASCO supports the flexibilities CMS has implemented to ensure telemedicine is available to more patients and practitioners during the PHE, and we urge CMS to strengthen its proposal by making those expanded telemedicine policies permanent after the expiration of the PHE.

Expansion of Coverage for Colorectal Cancer Screening and Reducing Barriers

• ASCO strongly supports CMS’ proposal to reduce the age limit and increase Medicare beneficiary access to non-invasive cancer screening tests and follow-up colonoscopies without any beneficiary cost sharing.

Advancing Cancer Care MVP

• We strongly urge CMS to postpone the release of the Advancing Cancer Care MVP to performance year 2024.
• We recommend that the Advancing Cancer Care MVP focus on medical oncology. We encourage CMS to create separate MVPs for surgical oncology and radiation oncology.
• ASCO reiterates its comments from last year; we do not support CMS’ proposal to sunset the traditional Merit-Based Incentive Payment System (MIPS) in favor of MVPs.

ASCO remains committed to working with CMS to help ensure access to high-quality, equitable cancer care for all patients.

Read the full comment letter.

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