Tag Archives: healthcare reform

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.

Why I’m Going to Capitol Hill On March 29

By Virginia Vaitones, MSW, OSW-C

U.S. CapitolACCC Capitol Hill Day 2017 happens to coincide with national Social Work Month, which the National Association of Social Workers is marking with theme Social Workers Stand Up.  As an oncology social worker, this year I’m putting on my patient advocate’s hat, standing up, and going to Capitol Hill to share with legislators the stories of how my patients are being impacting by worry and uncertainty about how  changes to the Affordable Care Act and the Medicaid program may affect their insurance coverage and access  to care.

My home state of Maine has the distinction of having the oldest population in the country per capita and Knox County, where I live and work, has the oldest population in the state.  Many of my patients who are on Medicare also have MaineCare (Maine’s Medicaid program) as their secondary insurance.  The current proposed changes to how the federal government supports states with Medicaid funding will have a tremendous impact on my patients.

Besides the elderly population that I need to advocate for, the proposed cuts and changes in payment will have an impact on my younger patients who become disabled with their cancer diagnosis and depend on Medicaid to cover the cost of their cancer treatments.  As a patient advocate, I will be standing up for these patients as well.

My advocacy skills also are needed to bring the stories of how cancer impacts parents, small business owners, and working adults with a cancer diagnosis, who for the first time were able to afford health insurance under the ACA and now face uncertainty about whether they will have coverage or be able to continue to afford the cost of coverage.

Last but not least, I work in a rural community hospital whose doors are always open and that will treat patients whether or not they have insurance coverage.  I need to advocate for my hospital so that we can keep our doors open.

Capitol Hill Day, March 29, will bring together ACCC members representing cancer programs from across the country.  Together we will be standing up for our patients, for access to quality care close to home, and for our cancer programs.


Virginia Vaitones, MSW, OSW-C, is oncology social worker at Pen Bay Medical Center in Rockport, Maine, and a past president of the Association of Community Cancer Centers (ACCC). 

Speak Up Now!

by Leah Ralph, Director of Health Policy, ACCC

U.S. CapitolFor this year’s ACCC Capitol Hill Day, Wednesday, March 29, ACCC advocates will descend on Washington, D.C., with newfound motivation. As Congress grapples with the future of the Affordable Care Act (ACA) and debates the merits of protecting patients with pre-existing conditions vs. high-risk pools, refundable tax credits vs. subsidies, requirements for essential health benefits vs. more flexibility in benefit standards, oncology care providers see insurance coverage—and their patients’ access to cancer care—at stake.

Yes, It’s Complicated
The political messaging—not to mention policy minutiae—is difficult to sort through, even for the wonkiest of policy wonks in Washington. The ACA has been plagued with insurer drop outs and significant premium increases for the unsubsidized individual market, but the law has also provided critical patient protections, put an end to discriminatory practices by insurers, and covered 20 million new lives through Medicaid expansion and the health insurance exchanges. Having made ACA repeal their rallying cry for years, Republicans are now trying to find a path forward to make changes to the law. But maintaining those critical (and politically popular) patient protections, preserving essential benefits, and covering more people while also reducing costs for both the system and the patients is far from an easy task.

Preserve Patient Protections
More than ever before, this year on Capitol Hill Day, ACCC members have a critical story to tell about the unique needs of cancer patients and the costs of their treatment. Cancer, in many ways, demonstrates the precise need—and role—for insurance. Cancer diagnoses are inherently unpredictable. Cancer patients can’t plan when they are going to be sick or what kind of insurance they will need to cover their costs. In addition to the personal, emotional, and physical toll a cancer diagnosis takes on individuals and their families, cancer patients need good insurance to protect against the risk of catastrophic treatment costs.

The ACA created critical protections for consumers, including eliminating the ability of insurance companies to discriminate based on a pre-existing condition, like cancer, or to impose lifetime or annual dollar limits on policies. And by providing subsidies to those up to 400 percent of the federal poverty level to purchase insurance, the ACA made progress in closing the disparities gap in accessing cancer care.

Protect Patient Access to Care
In record numbers, ACCC members will set out on March 29 to educate Congress on what proposed changes to the ACA would mean for cancer patients and survivors and their ability to access high quality cancer care in the communities where they live and work. In the context of any ACA repeal and/or replace plan, ACCC members will ask legislators to:

  • Protect access to comprehensive, affordable insurance coverage. This is particularly critical for cancer patients facing high-cost treatments that often turn into chronic, long-term conditions.
  • Preserve critical patient protections, such as the ban on discriminating based on pre-existing conditions, no annual or lifetime limits, guaranteed issue, and allowing dependents to remain on their parents’ plan until age 26.
  • Preserve essential health benefits that require insurers to cover preventive services, like cancer screenings, at minimal or no cost-sharing.
  • Maintain meaningful access to clinical trials.
  • Strengthen patient access to adequate provider networks that include cancer specialists and the full range of services required to provide quality cancer care.
  • Meaningfully engage cancer patient and provider groups in any real effort to repeal and/or replace the ACA.

Beyond coverage and access, ACCC members will also reiterate their commitment to value-based care and any efforts to improve quality, affordability, and access in cancer care. ACCC has long been committed to working with the Centers for Medicare & Medicaid Services (CMS) to achieve true high-value, cost-effective cancer care. ACCC members support the mission and goals of the ACA-created Center for Medicare and Medicaid Innovation (CMMI), which has been the subject of recent scrutiny. More than half of the CMMI Oncology Care Model (OCM) participating practices are ACCC members. These forward-thinking practices are dedicating significant time and resources to making this pilot program work.

However, in the wake of last year’s CMMI ill-conceived proposed Part B Drug Payment Model, ACCC members will also strongly encourage Congress to place additional guardrails on CMMI’s authority, including limiting its scope to targeted, voluntary (rather than mandatory) demonstration programs.

ACCC members have a lot to communicate to busy Congressional representatives and staffers this year. But the stories we will share, from the communities in which ACCC members are working on the frontlines of cancer care, will bring home the impact of policy decisions in the clearest, most powerful terms. Now is a critical time to speak up and be heard—for our patients today and those who will become our patients tomorrow. Join us for ACCC Capitol Hill Day. Your story can make a difference.


The ACCC 43rd Annual Meeting, CANCERSCAPE, March 29-31, will provide a 360-degree look at the healthcare landscape from the Democrat and Republican perspectives with insights on what to expect for reimbursement, alternative payment models, drug pricing, quality reporting, and more. Learn more.

On the Road to Value-Based Care: Operational & Cultural Change

By Monique J. Marino, Senior Manager, Publications & Content, ACCC

2017-Open-Road-smWhile there can be no single roadmap for transitioning to value-based care, a panel session at the 2017 Cancer Business Summit, February 6-7, 2017, co-hosted by the Association of Community Cancer Centers, focused on  Operational & Cultural Change  that can help cancer programs move forward on the path ahead.  Sarah Chavarria, Chief People Officer, NantHealth, shared that successful organizational alignment is centered around these key concepts:

  • Strategy: mission, vision, and values; organizational goals; brand.
  • Structure: placing the right talent in the right role; holding people accountable for meeting organizational goals.
  • Talent: managing against a set of value-based competencies; assessing, developing, and growing the “best and brightest.”
  • Rewards: creating incentives that drive collaboration to deliver on organizational goals; these incentives should be flexible in design to attract and retain top talent—in other words, identifying what your employees value so that the organization can package them and reward behavior they want.
  • Systems and processes: these should enable decision making and responsiveness, and support effective execution.

“Cancer programs should create a ‘Deliberate Culture,’” Chavarria concluded. “If you are not deliberate in defining your culture, it will just happen; and it will not be what you want.”

Panelist James Grayson, a High Reliability Organization Specialist at West Cancer Center, outlined five key steps to help cancer programs succeed operationally and culturally:

Step. 1 Set your bar higher than everyone else’s.

Step 2. Hire people with potential.

Step 3. Invest in your front-line management team.

Step 4. Invest heavily in safety, risk management, leadership, and talent development.

Step 5. Be the cancer program your patients and staff need you to be.

Rounding out the panel was 2017 Cancer Business Summit Innovator Award Winner, Barry Russo, MBA, Chief Executive Officer, The Center for Cancer and Blood Disorders, who told attendees about the steps his cancer program took to move to value-based care, including:

  • Centralizing patient intake from 9 practice locations to 1 location, streamlining and improving care coordination.
  • Establishing triage as its own business unit.
  • Implementing an internal case management program to facilitate proactive intervention and risk stratification of patients.
  • Growing supportive care services (an effort that requires continual identification of new funding avenues), such as palliative care, chaplaincy services, nurse navigation, survivorship, etc.
  • Implementing a new patient education program.
  • Identifying technology gaps and improving decision-support around data and analytics.
  • Developing communication tools around value-based care to share with employer and payer communities.

To help cancer programs prepare for the change to value-based care, Russo offered five high-level takeaways:

  1. Deliver a consistent message; identify the changes needed and understand how to make these changes.
  2. Establish a new norm—while still a physician-centric care delivery model, ALL members of the care team are essential to healing lives after cancer. Value-based care requires cultural change and significant organizational re-engineering.
  3. Understand that staff and clinician education is a journey and not a destination. Accept that leadership must focus on education, re-education, and then more education. Effective team building requires repetition—leadership rounds, nursing forums, regular reports from pillars in the cancer program, etc.
  4. Be aware that nursing needs a hyper-focus. Nurses enjoy the most touch points with patients, so nursing stability is of the utmost importance to successful cancer programs.
  5. Build strong teams at EVERY level of the organization; teams that can process constant change. The move to value-based care is not for the faint of heart. Staff must be able to accept feedback; brutal honesty is essential to the process. Staff must accept that the move to value-based care means change is interrupting their day, not making it easier.

Learn more about what lies ahead for value-based care at the ACCC 43rd Annual Meeting CANCERSCAPE, March 29-31, 2017, in Washington, D.C. Join your peers to hear from leading experts and decision-makers about the evolving healthcare policy landscape, the latest on alternative payment models, data collection and quality measures, and more. Explore the meeting agenda here.

 

CMS Part B Drug Demo Unlikely to Move Ahead

By Leah Ralph, Director of Health Policy, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoJust before Thanksgiving, top Senate Democrats asked the White House not to issue a final rule on the Center for Medicare and Medicaid Innovation (CMMI) proposed Part B Drug Payment Model – a national program that would significantly reduce reimbursement for Part B drugs. This was  a good sign for our efforts against the proposal, and on November 21, we passed an important deadline for CMMI to release a final rule. We are now within a 60-day window of the new Administration taking office, which, if a final rule were to be released, due to a series of administrative rules in Congress, makes it much easier for the new Administration to simply pull back the rule rather than having to do it legislatively.

Simply put: we passed a critical deadline, and we’re very optimistic that we will not see a final rule on the Medicare Part B Drug demonstration for the remainder of the current Administration. ACCC spoke out strongly against this ill-conceived proposal. Hundreds of ACCC members weighed in with their members of Congress, and ACCC produced financial analysis that we shared with the committees of jurisdiction in both the Senate and House of Representatives that showed precisely how devastating cuts to Part B drug reimbursement under this proposed model would be on both practices and hospitals. ACCC thanks you for your efforts to block this poorly-conceived experiment. This is a victory for cancer patients and providers across the country who can now continue to provide high-quality cancer care close to home.

With a new year and a new Administration upon us, we will continue to face both opportunities and challenges in the oncology policy landscape. ACCC is committed to preserving the cancer delivery infrastructure, and we will continue to work with policymakers to develop thoughtful policies around value-based care and an appropriate, sustainable reimbursement system for all settings of care.

Connecting the Moonshot to Patients

By Amanda Patton, ACCC Communications

ACCC President Jennie R. Crews, MD, MMM, FACP, welcomes conference attendees.

ACCC President Jennie R. Crews, MD, MMM, FACP, welcomes conference attendees.

The Cancer Moonshot framed Thursday’s  sessions at the ACCC 33rd National Oncology Conference in St. Louis. “I’ve been privileged to be part of the conversations around the Moonshot,” ACCC President Jennie R. Crews, MD, MMM, FACP, told attendees in her opening remarks. On Monday Dr. Crews participated in panel discussion at the White House as part of the Moonshot Task Force Report unveiling. With a goal of making a decade’s worth of progress in cancer prevention, diagnosis, treatment, and care in five years—it’s an “audacious” initiative that will bring challenges and significant opportunities to community oncology, she said.

In a heartfelt video message to conference attendees, Vice President Joe Biden, called community cancer centers the “bridge” between the Moonshot and cancer patients. “For the overwhelming majority of those patients who are diagnosed [with cancer], the next step leads to you,” he said. “Community oncologists treat as much as 85 percent of cancer patients . . . .Not only do your patients need you, your country needs you.”

It was a message reiterated at the end of the day by Anabella Aspiras, Director for Patient Engagement, Cancer Moonshot Task Force, in a session exploring how the Cancer Moonshot will affect providers in the community setting. “You truly connect the work of the Cancer Moonshot to cancer patients,” she told attendees. Ms. Aspiras highlighted the three Moonshot reports announced on Monday:

The Vice President’s Executive Report, a summary of work accomplished to date and challenges that must be addressed, which was presented to President Obama on Monday. The report outlines five strategic imperatives:

  • Realign incentives in the research system
  • Enhance prevention efforts
  • Engage patients as partners in research
  • Expand access to care
  • Convene a national conversation about cost.

The Task Force Report, covers the implementation plans for accelerating progress and includes Moonshot efforts underway over the past year.

The Blue Ribbon Panel Report, which integrates feedback into the panels 10 recommendations.

Anabella Aspiras and Jennie R. Crews, MD, MMM, FACP, at the ACCC National Oncology Conference.

Anabella Aspiras  with ACCC President Jennie R. Crews, MD, MMM, FACP, at the Cancer Moonshot Report unveiling earlier this week.

In her remarks, Ms. Aspiras called attention to existing ACCC initiatives that support the Blue Ribbon Panel recommendations, including the Institute for Clinical Immuno-Oncology (ICLIO) and ACCC’s educational work related to integrating biomarker testing in the community setting.

In her role at the Moonshot Task Force, Ms. Aspiras’ primary responsibility is to represent the voice of the patient in four areas: addressing cancer inequities, enhancing community cancer care, improving clinical trial participation (accrual and retention) in particular in terms of under-represented populations; and survivorship. Research must benefit all segments of society, Aspiras said. “We must ensure advances in treatment are distributed equally.”

In closing, Ms. Aspiras thanked ACCC members for the work they do. “You bridge the gap between our efforts on the Cancer Moonshot and the patients we aspire to reach,” she said. “Every day you change the face of cancer as we know it.”

Stay tuned for more from the ACCC 33rd National Oncology Conference. Follow the conferences highlights on Twitter #ACCCNOC.

 

CMS Eases MACRA Quality Payment Program Timeline

By Leah Ralph, Director of Health Policy, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoIn response to considerable pressure from industry stakeholders, medical groups and policymakers, the Centers for Medicare & Medicaid Services (CMS) announced last week that it would provide increased flexibility for practices to report out and comply with new data and performance requirements under the Quality Payment Program (QPP), created by the Medicare Access and CHIP Reauthorization Act (MACRA) passed last year.

In a blog post titled “Plans for the Quality Payment Program in 2017: Pick Your Pace,” Acting CMS Administrator Andy Slavitt lays out four pathways to compliance with the new Quality Payment Program (in order of easiest to the hardest):

  • Report some data.  Providers can avoid a negative penalty by submitting some data as required by the Quality Payment Program, including data from after January 1, 2017. CMS states this option is “designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019.” This option allows you to avoid a negative payment adjustment in 2019.
  • Participate for only part of the calendar year. Providers may submit data as required by the Quality Payment Program for a reduced number of days (not the whole year), and the performance period could begin after January 2017. Under this option, you could still qualify for a small positive payment adjustment in 2019.
  • If you’re ready to go in 2017, participate for the full calendar year. For practices that are ready to go and choose this option, their performance period will begin January 1, 2017, and they will submit data under the Quality Payment Program for a full year. These practices will qualify for a modest positive payment adjustment in 2019. CMS expects many practices will be able to do this.
  • Participate through an Advanced Alternative Payment Model (APM).** While the three previous options would fall under the Merit-Based Incentive Payment System (MIPS) track, the fourth option allows providers who are receiving a certain percentage of Medicare payments or seeing a certain number of Medicare patients through a qualifying APM (the provider is taking two-sided or “more than nominal” risk) to participate through the Advanced APM track. These providers would qualify for a 5% incentive payment in 2019 in addition to any savings produced through the APM and would not be subject to MIPS requirements. (**Remember CMS lays out a very high bar to qualify for the APM track in the proposed rule: 90% of physicians are expected to choose MIPS).

Until 2019, physicians will see an annual 0.5% increase in payments, at which point payments will then be determined by performance in the Quality Payment Program either through MIPS or an advanced APM.

CMS has said the decision to provide leniency was in recognition of the “wide diversity of physician practices.” The agency has also said it is considering alternative start dates, shorter performance periods, increased flexibility for small or rural practices, and finding other ways for physicians to get more experience with the program requirements before being penalized.

CMS originally proposed that providers begin to report on measures outlined under the Quality Payment Program in January 2017 but that payments would not reflect that performance period until 2019. However with the new guidance from CMS, the easiest option essentially does not require real provider participation in 2017, but allows providers to test whether their systems are ready to fully participate in the future. While the details of the measures will remain unclear until a final rule is released, the Quality Payment Program will require practices to submit information on quality measures, how they use technology, and what improvement activities they are undertaking.

Through our comments to the agency in  June, ACCC advocated for increased flexibility and more time for physicians to prepare for undertaking the new requirements under the Quality Payment Program. We also asked the agency to restructure the APM requirements so that they are more achievable.

We commend CMS for releasing flexibility prior to a final rule on MACRA, which we expect to see later this fall, and ask for continued accommodations for practices that face myriad new requirements in the coming months and years.

Will Spending More on Healthcare Result in Better Cancer Outcomes?

by Chad Schaeffer, MS, FACHE

Healthcare costsA recent study published in the Journal of the National Comprehensive Cancer Network finds that spending more on healthcare does not always correlate to better outcomes.  The authors of the article, “Wealth, Health Expenditure, and Cancer: A National Perspective,” studied different areas of the U.S. and looked at the wealth, spending, and cancer outcomes for breast cancer, colorectal cancer, and all cancers.1

The researchers, led by Dr. Jad Chahoud, point out that in 2013 the U.S. spent $2.9 trillion on healthcare—more than any other country—yet ranked 27 in life expectancy compared with the 34 countries that comprise the Organization for Economic Co-operation and Development (OECD).  Their conclusion is that the U.S. healthcare system is flawed by an unequal resource allocation and socioeconomic disparities. This has long been the case when the U.S. is compared to many European countries, which have universal healthcare or a single-payer system and access to healthcare is often more consistently available to all citizens.

However, things get very interesting when the researchers compare different regions within the U.S. and find differences in cancer outcomes. When looking at colorectal cancer and all cancers, the common theme is that wealthier states, such as New York, Illinois, and California, tended to have better outcomes compared to the least wealthy states, such as Mississippi, West Virginia, and Alabama. The wealthier states spent more per capita, but not necessarily for healthcare. For instance, West Virginia spent more on healthcare per capita ($7,667.14) than Illinois ($6,756.36), but the outcomes for colorectal and all cancers are better in Illinois.

 

 

State

Mortality/Incidence Ratio (colorectal cancer) Mortality/Incidence Ratio
(all cancers)
Illinois 0.3652 0.3823
West Virginia 0.3936 0.4306

Yet for breast cancer, the researchers discovered that paying more did correlate with better outcomes.  They surmise that this could be the result of effective breast cancer screenings and an overall high level of breast cancer awareness.

Takeaways

As I read the article and the findings from the study, two or three points come to mind. The first point is that since the extra spending on healthcare was effective for breast cancer, and—if the authors are correct that screening was a major factor—this could be good news for colorectal cancer if we can continue to improve screening rates. The second point is that with the new emphasis from Medicare and other payers on paying for quality, perhaps there will be an improved value in our healthcare system, leading to better outcomes. The last thought is that with the Affordable Care Act in place for several years and more Americans now having health insurance, and with a greater emphasis on screenings, would this potentially change the outcomes?  It is too early to say for certain, but if screenings rates improve, this will likely make a difference in overall outcomes.  We will have to wait and see.

References
Chahoud J, Rieber AG, Semaan A. Wealth, health expenditure, and cancer: A national perspective. J Natl Compr Cancer Netw. 2016;14:972-978.


ACCCBuzz contributing blogger Chad Schaeffer, MS, FACHE, is Executive Director of the Edwards Comprehensive Cancer Center at Cabell Huntington Hospital. He serves on the ACCC Editorial Committee.

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.

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.