In a comment letter to the Centers for Medicare & Medicaid Services (CMS) ASCO expressed significant concerns that provisions in the 2019 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule would undermine Medicare beneficiary access to cancer care due to reimbursement cuts based on site-of-service that fail to address systemic payment deficiencies for cancer care services under Medicare. ASCO urges CMS to forego implementing any additional utilization management strategies and instead enhance patient access to cancer care by facilitating participation in Advanced Alternative Payment Models (APMs) that use oncology clinical pathways to promote high-quality cancer care. 

“Before CMS implements additional policies that would impose across-the-board reductions in payments for cancer services, the agency should implement additional Advanced APMs that focus on promoting high-quality and high-value oncology care across all ambulatory settings,” writes ASCO President Monica M. Bertagnolli, MD, FACS, FASCO in the letter to CMS. “Arbitrary and overly-simplistic cuts based on finding and applying the lowest payment rate across all ambulatory settings undermine access in predictable and unpredictable ways and remove resources from cancer care without any consideration of the value or sufficiency of current payment levels.”

Highlights from ASCO’s comment letter include

• Urging CMS to not finalize proposals to reduce payment based on site-of-service. ASCO opposes reductions in cancer care resources that are determined merely by picking the lowest cost among treatment settings.
• Urging CMS to not finalize changes to HOPPS that would diminish patient access to cancer care services in any setting of care.
• Urging CMS to not finalize significant payment reductions for Part B drugs purchased through the 340B drug pricing program.
• The society supports billing and coding changes proposed by the Advisory Committee for CAR-T services.
• Consideration of a competitive acquisition program (CAP) should proceed with caution.  CAP should only be tested in the context of a voluntary demonstration program and be designed in collaboration with key stakeholders.

More on the Competitive Acquisition Program

ASCO’s comments include responses to CMS’ “Request for Information (RFI) on Leveraging Authority for the Competitive Acquisition Program (CAP) for Part B Drugs and Biologicals for a Potential CMS Innovation Center Demonstration,” which was included in the HOPPS rule publication. This RFI builds on the HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs on Drug Pricing, and Request for Information, which was released in May 2018.

ASCO is also concerned about the rising cost of cancer drugs, and the society is ready to work with CMS on alternative ways to promote patient access to oncology care while helping oncology practices remain economically viable. Furthermore, there are a significant number of independent oncology practices that may be interested in participating in a CAP demonstration model—but only if participation is fully voluntary, designed to avoid reductions in resources devoted to cancer care, assures timely patient access to oncology treatments, promotes efficiency, and prohibits the use of draconian utilization management policies. 

“We urge CMS to be cautious in its development and implementation of any CAP Demonstration Model and to restrict its initial scope to Medicare fee-for-service,” writes Dr. Bertagnolli in the letter.

Read the full comment letter.   

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