Tag Archives: ACCC advocacy

House Subcommittee Hearing Focuses on HRSA’s Oversight of 340B

by Blair Burnett, Policy Analyst, ACCC

U.S. CapitolThis week, the U.S. House of Representatives Subcommittee on Oversight and Investigations, of the Energy and Commerce Committee, chaired by Rep. Tim Murphy (R-PA), held a hearing titled, “Examining HRSA’s Oversight of the 340B Drug Pricing Program.” Health Resources and Services Administration (HRSA) is the agency within the U.S. Department of Health and Human Services that currently oversees the 340B Drug Pricing Program. The program’s inception in 1992 sought to provide discounted outpatient drugs to “covered entities” (DSH facilities, rural referral centers, freestanding cancer centers, non-profit hospitals, etc.) who provide a certain level of care to Medicaid and low-income Medicare patients, allowing covered entities to stretch scarce federal resources to provide affordable prescription drug coverage to all patients.

The hearing, convened on Tuesday, July 18, addressed how HRSA’s oversight can improve review of eligible healthcare facilities utilizing the program in the face of continued expansion of facilities that qualify. As of October 2016, there are 12,168 covered entities utilizing the 340B Drug Pricing Program, and this number has quadrupled since 2011. The hearing also sought to explore how HRSA can be more transparent with 340B Drug Pricing Program reporting, calling attention to gaps in current data collection efforts.

Witnesses who testified at the hearing included:

  • Krista M. Pedley, PharmD, MS, CDR, USPHS, Director, Office of Pharmacy Affairs, Health Resources and Services Administration, U.S. Department of Health and Human Services;
  • Debbie Draper, Director, Health Care, Government Accountability Office (GAO); and,
  • Erin Bliss, Assistant Inspector General, Office of Evaluation and Inspections, Office of Inspector General (OIG), U.S. Department of Health and Human Services.

Both the office of the GAO and HHS OIG have done significant work with the 340B Drug Pricing Program, and the witness testimony spoke to the recommendations both have made to HRSA. Both offices have also repeatedly reviewed HRSA’s regulatory capabilities with the 340B Drug Pricing Program and stated the need for more robust oversight. Based upon witness testimony and member questioning, key takeaways include:

  • Possible bipartisan legislation efforts that seek to grant HRSA more oversight of the 340B Drug Pricing Program.
  • Increased transparency from HRSA on 340B Drug Pricing Program costs and rules.
    Multiple members called for insight into how covered entities are utilizing any savings accrued from the 340B Drug Pricing Program. Within the current oversight from HRSA, there are no guidelines on how covered entities utilize or report 340B Drug Pricing Program savings.
  • Additional hearings to examine the 340B Drug Pricing Program within the subcommittee bringing in physicians and hospital executives to ask healthcare facilities how they are utilizing savings acquired from the 340B Drug Pricing Program.

Notably, this hearing convened shortly after the July 13 release of the Centers for Medicare & Medicaid Services (CMS) proposed 2018 Outpatient Prospective Payment System (OPPS) rule, which calls for a drastic reduction in Medicare Part B payments for outpatient drugs to all covered entities utilizing the 340B Drug Pricing Program from average sale price (ASP) plus 6 percent to ASP minus 22.5 percent in an effort to reign in the program. Rep. DeGette (D-CO), Rep. Schakowsky (D-IL), and Rep. Pallone (D-NJ) voiced concern over this proposal and called for bipartisan support to make meaningful reforms to the 340B Drug Pricing Program to ensure HRSA oversight is effective in aligning transparency as well as improved facility and overall data audits.

As policymakers continue to shine the light on the 340B program, over the next several weeks ACCC will continue to monitor efforts to reform the program and evaluate the impact the OPPS proposal will have on ACCC membership. Along with other stakeholders and coalition partners, we will be forcefully advocating for policies that are in the best interest of all community-based providers and their patients.


ACCC members can gain an in-depth understanding of how CMS’ proposed CY 2018 Medicare rules will impact oncology by participating in ACCC’s August 9 webinar, “CMS Proposed 2018 OPPS & PFS Rules: What You Need to Know.” Learn more [member log-in required].

Update from Capitol Hill

By Brittney Fairman, MPS, MA, ACCC Policy Analyst

U.S. CapitolAt the end of last week, it was anticipated that the U.S. Senate would hold a vote on the Senate Republicans’ revised version of the Better Care Reconciliation Act (BCRA) today, Tuesday, July 18. However, over the weekend,  Senator John McCain (R-AZ) underwent an emergency surgery and Senate Majority Leader Mitch McConnell (R-KY) announced that the vote on BCRA would be postponed until Senator McCain’s return to Washington, D.C. With two Senators, Rand Paul (R-KY) and Susan Collins (R-ME), already openly opposed to voting ‘Yes’ on BCRA—Senator McCain’s absence would have put the Republican Senators’ vote on the bill at risk.

In order to continue the repeal and replace of the Affordable Care Act (ACA), Senate Republicans would need at least 50 of the 52 Senate Republicans to vote in favor of BCRA.

On Monday evening, the bill took another turn when Senator Mike Lee (R-UT) and Senator Jerry Moran (R-KS) jointly announced their opposition of a motion to proceed on the revised healthcare bill. These two additional defections on Senator McConnell’s bill means the Senate Majority does not currently have the votes to even begin debate on the legislation to repeal and replace the Affordable Care Act (ACA).

So at this point, the future of BCRA remains uncertain. On Monday evening, Majority Leader McConnell stated, “Regretfully, it is now apparent that the effort to repeal and immediately replace the failure of Obamacare will not be successful.” President Trump has suggested the Senate Majority move forward in repealing the ACA without immediate replacement.  In this scenario, the Senate would vote in the coming days on a bill which would delay the ACA’s repeal for two years as Republicans work on individual bills to dismantle the current healthcare law.

ACCC will continue to monitor the Senate’s actions and keep ACCC members posted with the latest updates.

What Happened in Washington This Week

By Brittney Fairman, MPS, MA, ACCC Policy Analyst

U.S. CapitolIt’s been quite a week in Washington, D.C.  Let’s recap.

On Wednesday, July 12, the Centers for Medicare & Medicaid Services (CMS) held the latest in a series of webinars explaining the agency’s proposed rule for CY 2018 updates to MACRA’s Quality Payment Program. If you missed ACCC’s webinar on the implications of this proposed rule, members can access the webinar, presentation slides, and a summary [login required].

On Thursday morning, July 13, U.S. Senate Republicans unveiled their revised draft of the Better Care Reconciliation Act of 2017 (BCRA). The updated bill is the latest effort to repeal and replace the Affordable Care Act (ACA), and we continue to have concerns about the erosion of protections for cancer patients in the exchange marketplaces. ACCC is continuing to monitor the effort on the Capitol Hill and measure the evolving legislation against ACCC’s health reform principles.

Then later that same day, the Centers for Medicare & Medicaid Services (CMS) released the proposed CY 2018 Hospital Outpatient Prospective Payment System rule and CY 2018 Physician Fee Schedule rule. ACCC is currently analyzing both rules and will provide in-depth information to members on the impact on oncology. At first glance, the proposed, significant cuts to hospitals in the 340B Program and to new outpatient facilities cause concern, particularly for small, rural cancer programs and programs in vulnerable communities without other sources of healthcare. Stay tuned for information on the date and time of an upcoming ACCC members-only webinar on these proposed rules.

Also Happening on Capitol Hill
So this week, while much of the nation’s attention has been focused on Congressional action on ACA repeal and replace, and many healthcare providers awaited CMS’s release of the proposed 2018 Medicare rules, it’s important to note that another significant piece of legislation moved forward on Capitol Hill. On July 12, the U.S. House of Representatives passed the FDA Reauthorization Act (HR 2430). This legislation includes important bills for cancer care, including the Research to Accelerate Cures and Equity (RACE) Act and reauthorization of the Prescription Drug User Fee Act (PDUFA), which allows the FDA to collect fees from drug manufacturers to fund the new drug approval process. The User Fee Program plays an important role in the timely review of new drug applications and patients’ ability to access novel therapies.

The “RACE” Act is a bill which has important implications for the fight against childhood cancer. The legislation specifically updates the 2003 Pediatric Research Equity Act (PREA), which requires studies of adult drugs in adolescents during a drug’s development process.

PREA has experienced success in providing important information on a drug’s use in children in hundreds of cases; but, it has not yet been applied to pediatric cancer drugs. It is well known within the oncology community that many pediatric cancer patients are typically treated with “off-label” adult drugs. Under the RACE act, the FDA will be given authority to require a pediatric investigation into adult drugs if those drugs use molecular targeting and that same target is “substantively relevant” to the continuance of a pediatric cancer. If passed in the U.S. Senate, this act will permit clinicians to know the dosage, safety and efficacy in pediatrics and grant accurate labeling for use on children. Additionally, the RACE act will mandate that molecular targeting drugs be given an orphan designation to go through a pediatric investigation.

As summer in Washington continues to heat up, ACCC is closely monitoring legislation on Capitol Hill and performing an in-depth analysis of CMS’s proposed rules for 2018. Stay tuned for updates.

 

ACA Repeal & Replace Update: Senate Republicans Put Their Cards on the Table

By Brittney Fairman, MA, MPS, Policy Analyst, ACCC

U.S. CapitolLast Thursday, June 22, Senate Republicans publicly unveiled their discussion draft legislation titled, the Better Care Reconciliation Act—their version of the House’s recently passed American Health Care Act (AHCA) (H.R. 1628). Neither bill was drafted under regular order, as Republicans try to maintain steam in pushing forward with the repeal and replacement of the Affordable Care Act (ACA). Unfortunately, for multiple stakeholders, including many of those within the cancer care community, it is questionable how much the Republican Caucus sought patient and provider feedback to incorporate into their bills.

Although there was much speculation that the Senate version of the AHCA would undergo an entire re-write, the legislation released last week represents more of a fine-tuning of the House AHCA bill. Much of the Senate draft’s language reflects that found within the AHCA. The Senate bill contains various tax cuts for mostly high-income Americans; maintains the elimination of the individual and employer mandates; proposes less generous premium subsidies for those with lower household incomes; holds onto the AHCA’s similarly deep cuts to the Medicaid program—phasing out the expansion over three years and transitioning to a capped financing structure which essentially re-shapes the program’s funding; changes state adjustment-of-age bands by allowing insurers to increase the ACA’s ratio from allowing insurers to charge up to three times more for older individuals to permitting insurers to charge up to five time more; and still allows states to apply for waivers to overhaul their insurance markets (including the option of ending the essential health benefit requirement and potentially reinstating annual and lifetime coverage gaps).

There are, however, several notable changes within the “draft” Better Care Reconciliation Act signaling some improvement from the House bill. This Senate version would require insurers to cover people with pre-existing conditions and ban them from charging higher premiums because of their health history. But there is a caveat—there would not be an essential health benefit (EHB) requirement. This means that insurers would be able to offer less comprehensive policies that may or may not cover a patient’s treatment for pre-existing condition(s). Additionally, for individuals with household incomes between 100 percent and 200 percent of the federal poverty (FPL), authorized funding for cost-sharing reductions (CSR) payments would continue until 2020.

On Monday, June 26, the nonpartisan Congressional Budget Office (CBO) released a CBO score for the Senate legislation that finds the bill would result in 22 million more uninsured Americans by 2026, relative to the number under current law. This is slightly fewer than the increase in the number of uninsured estimated for the House-passed AHCA legislation.  According to the CBO score under the Better Care Reconciliation Act, by 2026 an estimated 49 million people will be uninsured, compared to the 28 million who will be uninsured that year under the current law.

A vote on the Senate bill is expected this week, leaving Senators with a relatively short window for reviewing the bill and also leaving stakeholders limited time to weigh in on the bill’s negative consequences for healthcare.

In a statement, the Association of Community Cancer Centers (ACCC) has expressed deep disappointment in the Senate’s draft legislation both in terms of policy and process, noting that the bill violates ACCC’s health reform principles.  ACCC believes this bill would be devastating for cancer patients and their families, and urges lawmakers to vote against the Better Care Reconciliation Act of 2017.  ACCC members can contact their Senators here.


Editor’s note: This post was updated on 6/26/17 to reflect release of the CBO score for the Better Care Reconciliation Act of 2017.

ACCC Expresses Serious Concern Over the AHCA

By Leah Ralph, Director of Health Policy, ACCC

U.S. CapitolOn May 4, 2017, the U.S. House of Representatives narrowly passed the American Health Care Act (AHCA), a bill that would repeal and replace key portions of the Affordable Care Act (ACA). The bill now heads to the Senate, where it faces significant concerns over the projected decrease in coverage and increase in cost, and will likely undergo a substantial re-write.

While the bill faces uncertainty, the Association of Community Cancer Centers (ACCC) remains very concerned about the impact the AHCA, as currently written, would have on cancer patients’ ability to access comprehensive, affordable health insurance coverage. The bill violates a number of ACCC’s health reform principles, which were central to our recent advocacy efforts on Capitol Hill.

Previous Congressional Budget Office (CBO) reports estimate that 24 million more Americans will be left without coverage under the AHCA, while disproportionately increasing out-of-pocket costs for elderly, low-income Americans in the individual and non-group markets. Recent amendments to the bill also weaken protections for patients with pre-existing conditions, like cancer, and the requirement that insurers cover defined Essential Health Benefits, such as cancer screenings. The current legislation also effectively rolls back the Medicaid expansion and proposes to fundamentally restructure the Medicaid program, inevitably shifting costs to the states and squeezing Medicaid benefits for low-income cancer patients across the country.

ACCC will continue to work with Congress to advocate for meaningful health reform policies that protect patient access to appropriate, affordable health insurance coverage and decrease costs for the patient and the healthcare system.

ACCC urges its membership to contact their Senators opposing the bill as currently written.

A Strong Voice in Challenging Times

By Amanda Patton, ACCC Communications

ACCC Capitol Hill Day 2017On Capitol Hill yesterday, in nearly 100 meetings with legislators and staff, ACCC advocates spoke out sharing the real-world impact of policy on cancer patients and cancer care delivery in communities across the country. Walking the halls of Congress were ACCC member physicians, nurses, administrators, pharmacists, social workers, financial advocates, and other members of the care team—from cancer programs and practices large and small—representing 23 states.ACCC Capitol Hill Day 2017

In conversations with legislators ACCC advocates urged that Congress:

  • Protect patient access to care, encompassing access to comprehensive affordable insurance coverage
  • Maintain meaningful access to clinical trials
  • Reject the NIH funding cuts proposed in the President’s FY 2018 budget and instead increase funding for NIH and the National Cancer Institute that is critical to our federal research infrastructure
  • Support federal oral parity legislation

Rep. Higgins-ACCC 2017 Hill DayDuring a lunch address, Congressman Brian Higgins (D-NY), who co-sponsors the Cancer Drug Parity Act of 2017 (H.R. 1409) told ACCC members, “Your constituents are our constituents,” and “your presence here [on Capitol Hill] is very important.”

In these challenging times, as Congress continues to deliberate reforms to our healthcare system, ACCC advocates spoke with a united, strong voice, encouraging their legislators to set aside politics and put patients first. Summing up the experience, Hill Day participant ACCC President Jennie R. Crews, MD, MMM, FACP, said, “Being on Capitol Hill today, it’s apparent that health reform is not dead and we need to remain vigilant that protections are there for our patients.”


ACCC Capitol Hill Day kicks off the ACCC 43rd Annual Meeting, CANCERSCAPE. Follow the meeting conversation on Twitter using #CANCERSCAPE as we live-tweet top takeaways. Stay tuned for blog updates with meeting highlights.

World Cancer Day 2017—Bringing the Message Home

by ACCC Communications

WCD_LOGO_4C“We can. I can.” This is the campaign slogan of World Cancer Day, an international campaign focused on increasing cancer awareness on the national, organizational, and individual level.

This February 4, 2017, the Association of Community Cancer Centers (ACCC) stands shoulder to shoulder with cancer care providers, patients, and families across the globe in recognition of World Cancer Day. Despite advances in diagnosis and treatment, each year more than 8 million people die of cancer worldwide. By the year 2025, this number is projected to increase to more than 11 million.

With the approach of World Cancer Day, ACCC salutes its members in cancer programs and practices across the country who are embodying the “We can. I can.” call to action every day, not only in caring for patients with cancer, but engaging their communities through outreach, education, and screening events throughout the whole year. Here are just a few recent examples of ACCC member initiatives:

ACCC acknowledges all of its members for their “we can” spirit that connects cancer programs and practices across the country in peer-to-peer learning—sharing knowledge, experiences, and solutions—to the benefit of the patients and the communities they serve.

ACCC Goes to Washington

By Leah Ralph, ACCC Director of Health Policy

With the transition to a new administration just days away, the Association of Community Cancer Centers (ACCC) this week joined with other leading cancer organizations to speak out for community cancer care providers and the patients they serve. On January 11, the Obama White House, in conjunction with Vice President Biden’s Cancer Moonshot initiative, hosted a morning-long event Making Health Care Better – Community Oncology.

ACCC-Delegation-at-the-White-House-sm

ACCC delegation at the White House

ACCC leadership—representing community providers from practices and cancer programs across the country—contributed to the conversation during moderated panel discussions, and provided real-world community perspectives on addressing disparities in access to prevention, diagnosis, and treatment; advancing clinical trials, new technologies, and innovative models of care; and providing support and survivorship services to patients with cancer. The event capped off a year’s worth of work between the Vice President’s office and oncology stakeholders across the country, including multiple meetings with ACCC members, to advance the priorities of Vice President Biden’s Cancer Moonshot Initiative and a commitment to achieving a decade’s worth of progress in cancer research in five years.  Don Graves, Counselor to the Vice President, thanked the cancer patients and providers in the room for their work to advance the goals of the Cancer Moonshot and, addressing the uncertainty around the future of the Vice President’s initiative, told the audience “the Cancer Moonshot will continue through you.” The Vice President recently announced he would start a nonprofit organization to continue to address the broad – and complex – issues around cancer research and funding. And late last year, Congress passed the 21st Century Cures Act, which provides $1.8 billion for Cancer Moonshot efforts at NIH.

ACCC-on-Capitol Hill-sm

ACCC Advocates Heading to Capitol Hill

In the afternoon, ACCC co-sponsored a Capitol Hill briefing on Innovation and Access in Quality Cancer Care. Addressing the uncertain political environment, Senator Jon Tester (D-MT) highlighted some of the achievements realized by the Affordable Care Act (ACA), while Representative Fred Upton (R-MI) and Representative Diana DeGette (D-CO) described the bipartisan effort behind passage of the 21st Century Cures Act. Advocates were assured that funding provided under the Cures Act will be secure, regardless of the fate of the ACA. Co-sponsoring the briefing along with ACCC were the Cancer Support Community, the American Cancer Society Cancer Action Network, the Community Oncology Alliance, McKesson Specialty Health, Sarah Cannon, and The US Oncology Network.

As the U.S. healthcare system continues to grapple with transformative change, sharing the story of cancer care delivery in communities where patients live, work, and vote is critical to helping policymakers and legislators understand the impact of policies, regulations, and legislation. Join ACCC for Capitol Hill Day on March 29, in Washington, D.C., and share your story.  Learn more here.

Fasten Your Seat Belts. . .

By Leah Ralph, Director of Health Policy, ACCC

Overlapping roadways As we head into the New Year, 2016 is rapidly receding in the rear view mirror. Still, it was quite a year. We saw the Obama Administration finalize regulations for sweeping physician payment reform in Medicare, oncology practices nationwide navigate the first year of the Oncology Care Model (OCM), policymakers try – and fail – to push through drug pricing reform with a national mandatory demonstration program, the 21st Century Cures Act signed into law, and the drug pricing debate hit a fever pitch, fueled by public scrutiny of recent spikes in drug spending and prompting a range of policy proposals to reduce spending on pharmaceuticals, raising bigger questions about how to define value in cancer care.

And after nearly eight years of a healthcare system shifting to achieve the aims – and requirements – of President Obama’s signature health reform law, the surprise election of Donald Trump and transition to a Republican administration and Congress who have prioritized repealing the Affordable Care Act (ACA) in early 2017 – combined with unprecedentedly thin policy prescriptions on the campaign trail – mark the beginning of an uncertain, tumultuous, perhaps even bumpy period for health policy. And fasten your seat belts because it may happen fast: the first 18 months of a new presidency and congress is the most active period of policymaking in the U.S.

ACA’s Uncertain Future

With respect to the ACA, while the health reform law encompasses far more than the insurance exchanges, the public debate to date has been focused on the coverage mandate and subsidies in the individual marketplace. It’s important to note that regardless of the election results, the health insurance exchanges are doing worse than expected. The exchange markets are facing sicker-than-expected risk pools and lower enrollment, causing high premium increases and insurer withdrawals. To survive, the exchanges would have needed stabilization under any administration – meaning a Trump Administration could simply leave the exchanges untouched and effectively allow them to wither on the vine, leaving 20 million uninsured.

But President-Elect Trump has signaled that he favors politically popular consumer protections in the ACA, such as banning insurers from discriminating against people with pre-existing conditions and allowing children to remain on their parents’ health plan until age 26. However the path to achieve this without a requirement that individuals either obtain coverage or pay a penalty remains unclear. And while there’s no agreed-upon replacement plan, Congressional Republicans have also supported allowing the sale of health insurance across state lines, expanding the use of health savings accounts (HSAs), replacing the ACA’s health insurance subsidies with tax credits, and establishing high-risk pools. But none of these proposals would meaningfully restore access to insurance coverage for the more than 20 million people who have gained coverage under the ACA, creating a long road ahead to find ways to cover this newly expanded population in any replacement plan.

What will these changes mean for cancer patients and providers? While the scope and details remain unclear, generally, under the proposals put forward to date, cancer providers may see an increased number of patients who are under- or uninsured, and higher uncompensated care costs. For the exchange population, benefits and cost-sharing assistance will likely be less generous, which could pose significant access barriers to quality cancer care.  At the same time it’s important to note that the ACA overpromised and underperformed – while patients without access to subsidies are seeing out-of-pocket costs spike, concurrently providers’ expectations of gaining fully insured patients under the ACA have not necessarily been realized. Patients with exchange coverage have generally been sicker and more expensive to treat and, on top of that, some providers are starting to see their Disproportionate Share Hospital (DSH) payments evaporate, as agreed to under the law. Fixes to the ACA – beyond what Republicans are proposing – are needed to shore up the long-term viability of our healthcare system for both patients and providers.

The Path Ahead

As the New Year rings in the changes in Washington, D.C., there will undoubtedly be significant impact on the direction of federal policy with respect to access and coverage in 2017. Still, we expect that key market trends such as value-based purchasing will continue. While the fate of the Center for Medicare and Medicaid Innovation (CMMI), which was created by the ACA, remains uncertain, we suspect that Medicare’s push towards value-based payment is inherently non-partisan and the movement to test different ways to pay providers based on cost and quality is here to stay. In fact, many experts predict that 2017 will be the year value-based purchasing moves from concept to reality. CMMI has implemented more than 50 demonstration programs. Some of these are becoming mandatory, including bundled payments for cardiac care and joint replacement.  (At the same time, the Republican-controlled Congress may create some guardrails for CMMI, including limiting its ability to implement mandatory demonstrations.)  Just around the corner, Medicare physician payment is shifting from fee-for-service (FFS) to value-based purchasing as required under MACRA . Reporting on MACRA measures begins in 2017 and will determine provider Medicare reimbursement in 2019. And the pharmaceutical industry is also engaged in value-based purchasing, increasingly pursuing outcomes-based contracts with private plans.

Where the Rubber Meets the Road

In 2017, ACCC members will need to consider how value-based payments will increasingly shift responsibility for managing cost and quality to providers, and how your cancer program is positioned to engage in a risk-based reimbursement structure. Providers should also prepare for a shift in coverage for patients, and anticipate how to respond to changes in access to care.

Now more than ever is the time for oncology care providers’ voices to be heard – join us in Washington, D.C., March 29-31 for ACCC’s annual policy meeting, Cancerscape, to understand how policy changes will impact your program and patients, engage in policy discussions with your colleagues, and help shape the future of healthcare policy in 2017 and beyond.  So buckle up, check out the Cancerscape agenda, and register today.

MACRA Update—Will CMS Delay the Start Date?

By Brittney Fairman, Policy Analyst, ACCC

Calendar pages and clockLast week Andy Slavitt, Acting Administrator for the Centers for Medicare & Medicaid Services (CMS), told the Senate Finance Committee that the agency was considering “alternative start dates,” for Medicare Access and CHIP Reauthorization Act (MACRA) after receiving more than 3,000 comments on its proposed rule implementing the Quality Payment Program. The final rule is expected in November, leaving only a few months before the proposed reporting start date of January 1, 2017. Slavitt also said the agency is taking a close look at how the proposed rule would impact rural and small providers, particularly the low volume threshold that would exempt small practices from certain reporting requirements.

In our June 27 comment letter on the MACRA proposed rule, ACCC urged CMS to:

  • Delay implementation for six months to one year, to give physicians the time needed to build infrastructure and implement the Quality Payment Program effectively
  • Ensure that the agency provides adequate accommodations and protections for small group practices and solo practitioners
  • Modify the “resource use” methodology to ensure that eligible clinicians are held responsible only for the costs they can control
  • Include all Oncology Care Model (OCM) quality measures in MIPS
  • Refine the APM requirements to offer a meaningful alternative to MIPS and adopt policies to promote the availability of a wide variety of APMs and Physician-Focused Payment Models (PFPMs).

With this proposed rule, CMS aims to transition Medicare to a new physician payment program focused on quality, value, and accountability over volume. The MACRA legislation enacted by Congress outlines essentially two separate payment pathways for physicians under Medicare: The Merit-Based Incentive Payment System (MIPS), and the Alternative Payment Models (APMs). Both pathways are intended to drive the development of value-based payment. ACCC supports payment reform efforts; however, it is critical that CMS construct these pathways so that they are realistic, achievable avenues to Part B reimbursement.

ACCC will continue to keep members informed as MACRA implementation unfolds. For a deeper dive on new requirements under the Quality Payment Program, ACCC members can access the recent ACCC webinar, “MACRA CMS Proposed Rule: What You Need to Know” on demand (login required). The American Medical Association (AMA) has created a MACRA Checklist that outlines steps providers can take now to prepare, as we await the final rule.