Tag Archives: ACCC advocacy

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.

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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.

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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.

Key Takeaways from Congressional Hearing on “Medicare Drug Experiment”

By Brittney Fairman, Policy Analyst, ACCC

Capitol BuildingOn Tuesday, May 17, the U.S. House Energy and Commerce Committee Subcommittee on Health held a hearing titled “The Obama Administration’s Medicare Drug Experiment: The Patient and Doctor Perspective,” which focused on CMS’ proposed Medicare Part B Drug Payment Model. The Subcommittee heard from witnesses representing the provider and patient communities, including:

  • Debra Patt, MD, MPH, MBA, Vice President of Texas Oncology and Medical Director of The US Oncology Network;
  • Marcia Boyle, President and Founder of the Immune Deficiency Foundation;
  • Michael Schweitz, MD, FACP, MACR, National Advocacy Chair of the Coalition of State Rheumatology Organizations;
  • Heather Block, a patient advocate; and
  • Joe Baker, President of the Medicare Rights Center.

Notably, the hearing echoed many of the concerns ACCC and fellow stakeholders have been voicing since CMS released the proposal in early March. Key takeaways include:

CMS is operating under a false premise that there are always less costly therapeutic equivalents available to treat patients. In the case of oncology, treatment situations where there are true clinical substitutes are “few and far between,” Dr. Patt pointed out. When a therapeutically equivalent drug does exist, those drugs are not always available to every clinician nor are they always most conducive to a patient’s specific treatment plan.

The proposed demonstration will create barriers to patient access and have a disproportionate impact on rural areas. With a lack of appropriate safeguards, healthcare providers fear the demonstration program would create additional financial pressures that would push rural or small physician practices out of business.  For patients in rural areas – or patients that require more expensive therapies – this may cause difficulty in accessing oncology care.

CMS’ proposal is akin to an involuntary clinical trial. Witnesses and Committee members pointed out that CMS’ experiment is not unlike a clinical trial, requiring participation of providers and their patients for the purposes of data collection. However, unlike a clinical trial, participation is involuntary and the proposal lacks critical patient safeguards – patients may never know if their provider is operating under a control or experimental arm of CMS’ demonstration. This randomized trial will, unknowingly and unwillingly, limit patient access to needed care.

Average Sales Price (ASP), by definition, is an average. Many community oncologists – often smaller practices – are not able to gain price advantages and are currently paying well above ASP for Part B drugs. Any further reductions to reimbursement will make it impossible for providers to cover the acquisition cost of many, if not most, cancer treatments.

Witnesses also addressed a series of “carve-outs” that have been discussed by policymakers, including for oncology providers, the Oncology Care Model (OCM) participating practices, or rural providers. Dr. Patt, however, pointed out that “there’s no right way to do the wrong thing.” Most witnesses called for a full withdraw of CMS’ proposal.

These points and more can be found in ACCC’s comments, submitted to CMS in early May. ACCC is continuing to monitor Congressional efforts on the CMS proposal.

ACCC Voices Part B Demo Concerns on Capitol Hill & at CMS

By Amanda Patton, ACCC, Communications

ACCC-PartB-Demo-Meeting-Capitol Hill-crop2With the Medicare Part B Drug Payment Model comment deadline fast approaching (Monday, May 9 at 5:00 pm EDT), ACCC continued its push to educate policymakers on the detrimental impact this ill-conceived proposal will have on community cancer care, providers, and patients.

This morning ACCC President Jennie R. Crews, MD, MMM, FACP;  ACCC Past President Ernest Anderson Jr., MS, RPh, FASHP; and Leah Ralph, Director of Health Policy, ACCC; together with representatives from the Hematology/Oncology Pharmacy Association (HOPA) and the Oncology Nursing Society (ONS), traveled to Capitol Hill to meet with Senate Finance Committee staff and discuss concerns about the Part B proposal’s impact on cancer care. During the meeting, ACCC shared information from a data analysis that reveals the significant financial impact the proposal would have on providers and patients.

In a meeting with CMS Center for Medicare and Medicaid Innovation (CMMI) staff on Monday afternoon, ACCC leadership, along with representatives from HOPA, and ONS—reflected the voice of multidisciplinary cancer care providers.  ACCC shared results from the Part B proposal data analysis and reiterated ACCC’s strong concerns that are reflected in our comment letter to the agency.  Read our comment letter.

Stay tuned for advocacy updates from ACCC.

 

ACCC Supports H.R. 5122, Legislation to Prohibit Medicare Part B Drug Demo

By Leah Ralph, Director of Health Policy, ACCC

Capitol BuildingThe Association of Community Cancer Centers (ACCC) thanks Representative Larry Bucshon (R-IN) for introducing H.R. 5122, legislation to prohibit further action on the Centers for Medicare & Medicaid Services (CMS) proposed rule for the Medicare Part B Drug Demo. ACCC urges prompt passage of H.R. 5122 in the U.S. House of Representatives.

ACCC remains strongly opposed to the Part B Drug Demo and is deeply concerned about the potential impact of this misguided proposal on both providers and the patients they serve.

Our membership, comprising approximately 2,000 practices and hospitals across the country, is committed to implementing value-based reforms and to continuing to work with CMS on meaningful payment reform—our members will be participating in the CMMI Oncology Care Model and investing in the infrastructure needed to comply with MACRA. However, CMS’ Part B Drug Model proposal is a nearsighted approach to Medicare reform.

ACCC supports H.R. 5122, and a full withdraw of the program, to provide the oncology community and CMS time to fully understand the impact of this policy and to work with CMS on meaningful reform.

For more on ACCC advocacy efforts on this issue, visit accc-cancer.org.

ACCC Asked: Congress Listened

By Leah Ralph, Director of Health Policy, ACCC

time for actionToday 242 members of Congress joined in a bipartisan letter to CMS Acting Administrator Andy Slavitt urging the agency to withdraw its proposed Medicare Part B Drug Payment Model.  The effort was spearheaded by House Ways and Means Committee Member and Budget Committee Chairman Tom Price, MD (R-GA), House Energy and Commerce Committee Member John Shimkus (R-IL), and House Ways and Means Committee Charles Boustany Jr., MD (R-LA).

You asked and Congress listened.  Last week, hundreds of ACCC members reached out to their legislators asking that they sign on to the Congressional letter to CMS.  ACCC thanks its membership from 2,000 cancer programs and practices across the country for speaking up and telling their legislators about the detrimental impact this proposed rule would have on their patients and providers.

But the question remains: Will CMS listen?

May 9 is the deadline for comments to CMS on this misguided proposal. ACCC will be submitting comments to the agency and urges its members to send comments as well.

Learn more about ACCC advocacy efforts on this issue here.

A Misguided Experiment?

By Leah Ralph, Director of Health Policy, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoThe noise around drug costs seems to have gotten louder in recent months, with policymakers clamoring for controls on drug pricing, Congressional hearings calling on pharmaceutical executives to testify, and recommendations from the Medicare Payment Advisory Commission (MedPAC) focused on containing Medicare spending in the context of ever-increasing prescription drug costs.

In early March, the Centers for Medicare and Medicaid Services (CMS) issued a proposal to implement a national demonstration program that would target provider reimbursement and fundamentally change the way Medicare pays physicians and hospitals for Part B drugs. The scope of what CMS is proposing is sweeping. If finalized, it represents a significant departure from the methodology and philosophy underlying Medicare’s current reimbursement system, leading to bigger questions about the most appropriate—and effective—way to curb drug spending.

Mandatory Participation

 CMS has broad authority under the Center for Medicare & Medicaid Innovation (CMMI), created by the ACA, to test different models that would improve quality and lower costs in the Medicare program. However, the agency seems to be pushing the scope of its authority, breaking from past demonstration programs to propose a mandatory model in which all Part B providers–hospital outpatient departments, physician offices, and pharmacies–would be required to participate.

The proposed Part B Drug Payment Model would consist of two phases in which providers would be divided into four groups: three experimental groups and one control group over a five-year period. Phase I would be implemented as early as August 2016 and would mandate that approximately half of all Part B providers would have their reimbursement rates reduced to ASP+2.5% plus a flat fee of $16.80 per drug per day. Importantly, Congressionally-mandated sequestration will continue to apply to payments made under the model. As a result, under the proposal, the experimental group’s actual payment rate will be ASP+0.86% plus $16.53 per drug per day. The remaining half, the control group, would continue to be reimbursed for Part B drugs at ASP+6%. The goal, which policymakers have discussed for sometime, is to eliminate financial incentives for providers to prescribe more expensive drugs.

Ambitious Timeline

The agency’s ambitious timeline calls for Phase II to begin as early as January 2017. Phase II would further divide the control and test groups—creating a four-arm control trial—and overlay a requirement to use value-based pricing (VBP) reimbursement strategies and clinical decision support (CDS) tools to produce Medicare savings. One (unlucky) group of providers will be subject to both the reduced ASP rate and the requirement to utilize VBP tools. These tools might include:

  • Reference pricing: Medicare would set a standard payment for therapeutically similar products.
  • Indications-based pricing: Payment would vary for a drug based on its clinical effectiveness for different indications.
  • Voluntary-risk sharing agreements: CMS would enter into voluntary agreements with manufacturers to link health outcomes with payment.
  • Discounting or eliminating patient coinsurance to encourage beneficiary use of high-value drugs.

Unanswered Questions

Despite a preliminary list of potential tools, CMS failed to describe these VBP approaches in any meaningful detail, leaving many questions about how CMS will develop this methodology and how the agency will make determinations about high-value treatments.

Perhaps most unnerving, providers would be assigned to arms of the trial at random based on their geographic location in Primary Care Services Areas (PCSAs), which are clusters of ZIP codes that reflect primary care service delivery. Although CMS has structured Phase I to be budget-neutral for the Medicare program, among providers, there will be winners and losers: the program is designed to redistribute drug spending by increasing payments to provider specialties, such as primary care, that use relatively inexpensive drugs and decrease payments to hospitals and physician specialties, such as oncology and ophthalmology, that often use more costly drugs. Specifically, under the proposed model, the tipping point is $480–drugs that cost providers more than $480 per day on average would result in lower reimbursement, whereas products costing less than $480 per day would produce higher payments than what is reimbursed today.

The majority of drugs–7 of 10–that would make up the largest reduction in reimbursement are used to treat cancer. Moreover, many of these drugs do not have a lower cost alternative.1

ACCC Takes Action

 On both policy and process, ACCC remains deeply concerned. Rather than working with cancer care professionals to build the infrastructure needed to define quality and value in their cancer programs, CMS has responded to a call for reigning in drug costs with a myopic focus on reimbursement. Our members have partnered with CMS on meaningful payment reform – including the most recent Oncology Care Model – and will soon be dedicating extensive resources to navigating a new, and complex, reformed physician payment system under MACRA.

Oncologists are ready for change, but CMS’ proposal reaches too far, too fast, with seemingly little understanding of the devastating impact this approach will have on community cancer care and patient access.

Early on, ACCC joined with 60 oncology stakeholder groups in a letter to CMS asking the agency to withdraw its proposal. On March 17 ACCC, together with more than 300 state and national organizations, sent a letter to Congress asking policymakers not to move forward with the CMS Part B Drug Payment Model proposal. We recently partnered with the Hematology/Oncology Pharmacy Association (HOPA), the Oncology Nursing Society (ONS), and the Association of Oncology Social Work (AOSW) to caution Vice President Biden about how the proposal would impede the goals of the Administration’s cancer Moonshot initiative.

CMS will accept comments on the proposal until May 9, 2016. ACCC will be submitting a comment letter and urges members to express their concerns to the agency.

Access ACCC resources related to this issue and learn more about our advocacy efforts here.

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This post was updated on April 26, 2016.

ACCC Advocacy Update

By Leah Ralph, Director, Health Policy, ACCC

U.S. Capitol Congress closed out 2015 with a bang, passing a number of large, end-of-year spending bills to keep the government funded through 2016 and several provisions that will impact ACCC members.

The omnibus appropriations bill (H.R. 2029) boosted NIH funding by 6.6 percent to $32.1 billion, the largest increase NIH has seen in 12 years. A separate package of Medicare provisions, the Patient Access and Medicare Protection Act (S. 2425) passed just before Congress adjourned for the year. This legislation created a blanket hardship exemption for meaningful use penalties in 2015, making it easier for the Centers for Medicare & Medicaid Services (CMS) to review and process hardship exemption requests. (To apply for an exemption, physicians must apply by March 15, 2016, and hospitals by April 1, 2016.)

The Medicare bill also froze payment rates to freestanding radiation therapy centers at 2016 levels for two years, CY2017 and CY2018. It is important to note that the Medicare bill ultimately did not include a provision that would have exempted “under construction” off-campus outpatient facilities from an earlier law (the Bipartisan Budget Act of 2015) that reduced Medicare payments to newly built or acquired hospital outpatient departments.

Before year-end President Obama signed both H.R. 2029 and S. 2425 into law.

As attention shifts toward elections in 2016, with divergent views on the future course of the nation’s healthcare policies, we are sure to see even more movement on policies that will impact the provision of quality cancer care. Make your New Year’s resolution today to join us for ACCC Capitol Hill Day March 2, 2016. Learn more and register here.