Tag Archives: Medicare

What Happened in Vegas: Highlights from the 2017 Cancer Center Business Summit

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

Person in information spaceLast week in Las Vegas, the Association of Community Cancer Centers (ACCC) co-hosted the 2017 Cancer Center Business Summit, a two-day conference focused on how the business of oncology is being transformed by the dual drivers of science and technology. Featured speakers and panelists from cancer programs, technology innovators, patient advocate groups, and payers came together to explore how new technology impacts the delivery and future of cancer care. Session topics highlighted clinical pathways, advanced alternative payment models (APMs), patient-centered care, genomic science, and more. Below are highlights from three conference sessions.

A session on Clinical Pathways: With What Result? looked at how the use of pathways and guidelines have changed clinical practice in oncology and created value. Panelist Marcus Neubauer, MD, Medical Director, Oncology Services, McKesson Specialty Health and The US Oncology Network, offered four forward-looking takeaways:

  1. Quality, performance, and resource consumption will be measured for ALL Medicare providers via MIPS (the Merit-based Incentive Payment System) or APMs.
  2. The value of drugs and technology will be scrutinized carefully by ALL providers—public and private.
  3. Adherence to clinical pathways is a cornerstone for value-based care models.
  4. Practices must transform to meet value-based requirements; provide enhanced services; and be able to negotiate reimbursement contracts with payers that support these aligned efforts.

The focus on new reimbursement models continued in a session on Alternative Payment in Oncology: Today & Tomorrow.  Panelists offered perspectives on their experiences with APMs to date and their outlook for the future. Kelly Blair, MPA, Vice President Consulting, Sg2, shared results from a member survey, which found that:

  • 64% of Sg2 members are NOT participating in oncology-specific value-based or alternative payment programs.
  • Operational issues were cited as the biggest barrier to participation.
  • Of those that are participating, 80% are participating in the Oncology Care Model (OCM).

Panelist Dave Terry, Chief Executive Officer, Archway Health, offered lessons learned implementing bundled payment models:

  • Develop accountable incentives in your bundled payment contracts.
  • Leverage data analytics.
  • Ensure specialist engagement.
  • Embrace innovation.

And panelist Cynthia Terrano, Vice President Payer Strategies, Moffitt Cancer Center, noted the importance of getting payers involved in the conversation. “The train has left the station on APMs,” she told meeting attendees. “Cancer programs need to reach out to their payers now to develop partnerships and experiment with different alternative payment models.”

With data collection a pivotal piece of value-based payment, what help might lie ahead for community oncology? In a discussion on Big Data Platforms to Support Community Oncology, panelist Robert S. Miller, MD, Vice President and Medical Director, CancerLinQ, shared his perspective of what the future may hold, including:

  1. Widespread data sharing.
  2. Meaningful penetration of actionable oncology-specific technology.
  3. Real insights gleaned from unsupervised machine learning applied to next generation sequencing (NGS) output.
  4. Big data platforms supporting external compliance reporting.
  5. Real-world evidence used in regulatory decisions.
  6. Greater structured data capture in EHRs embedded in clinician workflows—a culture change aided by technology solutions.

At the end of a busy two days of sessions, one message came across loud and clear—it will truly take a village to deliver cancer care in the 21st century. Beyond the multidisciplinary cancer care team, this village will include technology innovators that are designing the IT infrastructure necessary to move from fee-based to value-based care; third-party laboratories that process and interpret the genetic and genomic tests required to deliver personalized or precision medicine; and specialty pharmacies that are critical to patients accessing life-saving medications and the financial assistance services they need to afford them.


March 29–31, 2017, in Washington, D.C., the ACCC 43rd Annual Meeting CANCERSCAPE will bring together policy experts and key stakeholders from leading national organizations to share insights on the status of the Affordable Care Act and how value-based care, drug pricing reform, and changes to Medicare will affect cancer programs and practices. Learn more. Early Bird registration rates end Friday, February 17.

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.

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.

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.

_________________________________________

This post was updated on April 26, 2016.

ACCC Annual Meeting: Five Key Takeaways

by Amanda Patton, ACCC Communications

ACCC 42nd Annual MeetingNearly 500 oncology professionals gathered in Washington, D.C., last week for the 42nd ACCC Annual Meeting, CANCERSCAPE. Throughout sessions centered on policy, value, and quality, attendees heard a recurrent message: Your experience, perspective, and input on the issues of value-based care, quality measures, and outcomes are essential as the healthcare system and oncology transition to the new world of alternative payment models and value-based care.

From ACCC Capitol Hill Day last Wednesday throughout the meeting sessions, attendees were urged to educate policymakers and payers about the real-world processes involved in delivering quality cancer care.

In the meeting’s opening session, Congressman Rick Nolan (MN-D)  called out the vital role ACCC members can play in helping educate legislators and policymakers, “No one can articulate need, challenges, potential to ultimately cure cancer [better] than the people in this room today,” he said.

Can precision medicine be reconciled with value-based care? “Absolutely” said Kavita Patel, MD, MS, of the Brookings Institution.  Oncology already delivers personalized (or precision) medicine through targeted therapies for some cancers, she pointed out. Communicating about the oncology care process so that policymakers understand real-world cancer care delivery is imperative, Patel said. Part of that conversation should aim to help policymakers understand the demanding intuitive thought process that is part of today’s oncology care, along with the tremendous amount of information cancer care providers must keep up with given the pace and variety of emerging therapies. “It’s not writing prescriptions,” she said.

Five Key CANCERSCAPE Takeaways

High-level meeting takeaways that interconnect value, policy, and quality include:

  1. Alignment. For value and quality measures to work in oncology, alignment among payers, providers, and patients is essential.
  2. Put your data to work. Cancer programs and practices are finding ways to harness their data to improve quality patient-centered care and reduce costs. In a presentation on Collaboration Across Specialties to Improve Care and Curb Costs, Matthew Manning, MD,  from Cone Health demonstrated how his program used data to identify “hotspotters,” assess gaps in care, improve outcomes, and reduce costs.
  3. Communicate. Support conversations across silos and among stakeholders. Engage with patients to understand their goals of care and to define value and quality. While value frameworks are generic, “all patients are different” agreed panelists in a Town Hall discussion on Value Framework Tools.
  4. Be proactive. Don’t wait until USP Chapter 800 goes into effect to assess your facilities readiness. Don’t wait until HRSA issues its final 340B mega-regulation. Take steps today to assess your program’s compliance. “Be prepared” was also the message in a Biosimilars Update from Nisha Pherwani, PharmD, BCOP, clinical director of Oncology, Cardinal Health. She urged attendees to:
    • Understand the FDA approval process for biosimilars
    • Provide a concise review to your P&T committee
    • Review the FDA guidances on biosimilars
    • Stay tuned for more on how interchangeability will impact regulations.
  5. Speak up. Oncology providers can best articulate the care they provide and the issues impacting care delivery. Leadership in oncology has to step forward to help define quality and value and inform policy. Work with ACCC to make your voice heard.

This week’s CMS release of a proposed rule designed to test new Medicare Part B drug payment models makes clear the critical need for the oncology community stay on top of what is happening among policymakers in Washington, D.C.  ACCC has voiced strong opposition to CMS’s proposal. Among other concerns, ACCC points to the lack of opportunity for stakeholder input on the development of this proposal.

ACCC urges its members speak up and ask Congress to stop the CMS Medicare Part B Drug Payment Model.  Click here to contact your legislators.

Annual Meeting Highlight: Medicare Update & What to Expect in 2016

By Amanda Patton, ACCC Communications

ACCC 42nd Annual Meeting-ConwayAt the ACCC 42nd Annual Meeting last week, Lindsay Conway of The Advisory Board Company updated attendees on Medicare payments and what to expect in 2016.  Not surprisingly, her presentation touched on issues related to the meeting’s central themes of policy, quality, and value.

Two examples of the forward momentum in quality this year will be “testing” new oncology quality measures through PCHQR Quality Reporting Measures and CAHPS for Cancer Care.  Field testing for the CAHPS for Cancer Care is wrapping up, Conway said, and we can expect to see the CAHPS trademark on three oncology-specific surveys this summer.  Specifically, we will see a survey for surgical oncology, a survey for radiation oncology, and a medical oncology survey. Each survey will consist of about 85 questions and will likely reflect five CAPHS domains, including:

  1. Effective Communication
  2. Shared Decision Making
  3. Enabling Patient Self-Management
  4. Technical Communication
  5. Access

Looking ahead, Conway noted that new policies are supporting population health goals while also slowly moving forward with payment for value. As examples, she cited recent Medicare policies related to biosimilars, advance care planning, and lung cancer screening.

As cancer programs plan strategically for the future, Conway suggests keeping an eye on the following:

  • Payment equalization—which is gaining momentum
  • Progression of site-neutral payment policies
  • Physician practice acquisition—the equation is becoming increasingly complex from both the hospital and the physician practice perspectives
  • Alternative payment models (APMs), in particular the Center for Medicare and Medicaid Innovation (CMMI) Oncology Care Model.

The CMS OCM initiative, which will pilot a value-based reimbursement model in oncology, is on everyone’s radar screen, as the oncology community awaits the agency’s announcement of practices selected for participation. Conway acknowledged that the OCM model is complex and that many questions remain about how CMMI will implement the model.

The ultimate benefit for those participating in the OCM will not be financial, according to Conway. The benefits for participants will be strategic, e.g., new data sets, benchmarks, more data about the patients being served, the opportunity to develop competencies in operating in a risk-based environment, and having a voice in the development of new risk-based models in oncology.

Why ICD-10 Codes Must Tell Your Patient’s Story

By Amanda Patton, ACCC Communications

meetings-AM2016-brochure-190x246We’re four months post ICD-10 implementation and some are comparing the transition to Y2K—a lot of sound and fury over what ultimately turned out to be a relatively calm transition.

If you think it’s all smooth sailing from here on out, think again. “ICD-10 is nothing like Y2K,” says Cindy Parman, CPC, CPC-H, RCC, Principal, Coding Strategies, Inc. “Moving to ICD-10 is more like having a baby. Once the baby’s arrived the work begins.”

In a session on Friday, March 4 at the ACCC 42nd Annual Meeting, CANCERSCAPE, Parman will be sharing tips for cancer programs to take stock of their ICD-10 transition.

Post implementation, what ICD-10 pain points is Parman seeing in oncology programs?

· Coding errors.  These may be coder mistakes or they may stem from insufficient documentation in the medical record—for example, physicians not providing enough information.
· Productivity.  Working with ICD-10 is taking coders longer because there is more information to sift through and coders may have to go back to physicians with questions.
· Reimbursement issues.  Insurance payers are taking an opportunity to tighten up qualifications for reimbursement. Some ICD-9 codes may have been reimbursed in the past, where the corresponding ICD-10 code will not result in payment. Even smooth transitions to ICD-10 don’t necessarily mean that cancer programs are coding correctly, Parman warns.

“It’s important for cancer programs to understand that ICD-10 is a patient classification system,” says Parman. Used appropriately, the code set will generate the data that tells the patient’s story and ensure that providers are getting credit for all of the care that is being provided. But when codes are missed that story is incomplete.

New payment models will be driven by ICD-10 codes, and capturing all the care provided for patients is critical, Parman says. “The data that cancer programs are collecting today will be used by the Centers for Medicare & Medicaid Services (CMS) to develop future alternative payment models (APMs). If the codes used do not reflect the full scope of services provided, cancer programs won’t be able to go back later and say ‘we left these codes off.’ ”

During her meeting session, Parman will discuss the potential for mining ICD-10 data to measure quality, safety and efficiency, among other indicators. But, she points out, “You can’t mine data you don’t have.”

Join us at the ACCC 42nd Annual Meeting, CANCERSCAPE, from March 2—4, 2016, in Washington, D.C., and gain strategic insight into three key drivers of change impacting our evolving oncology care delivery system: policy, value, and quality. Full session and speaker information available here.

___________________________________________

Originally posted to ACCCBuzz on January 26, 2016.

Senate Postpones Decision on SGR

U.S. Capitol By Leah Ralph, Manager, Provider Economics and Public Policy, ACCC

On Thursday, March 26, the U.S. House of Representatives passed H.R. 2, legislation to permanently repeal and replace Medicare’s sustainable growth rate (SGR) formula for physician reimbursement. Read a summary of the legislation here.

Unfortunately, the Senate announced late Thursday evening that they will not consider the SGR repeal bill until they return from recess on April 13, 2015.  CMS has indicated it will hold claims for two weeks, through April 14.

ACCC urges members to contact your Senators in the next two weeks and ask them to support a permanent repeal of the SGR.

Bringing the Oncology Care Model into Focus

By Leah Ralph, Manager, Provider Economics and Public Policy, ACCC

imagesAs ACCC members are well aware, on February 12, the CMS Innovation Center (CMMI) released its much-anticipated Oncology Care Model (OCM) as part of the broader effort to lower healthcare costs and tie reimbursement to quality and value. ACCC has been conducting an in-depth analysis, and, overall, the OCM generally resembles the discussion draft we saw in August; while the model contains many positive elements, other areas still need clarification.

At its core, the OCM looks similar to a patient-centered oncology medical home or accountable care organization (ACO), with a target expenditure and shared savings component that encompasses the total cost of patient care during a particular period of treatment. The model is a voluntary, five-year program slated to begin in spring 2016. Physician group practices, hospital-based practices (except for PPS-exempt hospitals), and solo practitioners that furnish cancer chemotherapy are eligible to participate. Payments will be based on a six-month episode of chemotherapy treatment that is triggered by the administration of a pre-set list of chemotherapy drugs, and will take into account all Part A, Part B, and some Part D expenditures for that patient during the episode. In addition to a FFS payment, providers will receive a care coordination payment to improve quality of care ($160 per patient, per month during the episode) and a performance-based payment to incentivize lower costs that will be based on the difference between a risk-adjusted target price and actual expenditures during the episode. The payment arrangement is one-sided risk, with the option of converting to two-sided risk in the third year.

Importantly, the OCM is a multi-payer model in which commercial payers and state Medicaid agencies are encouraged to participate. Aligning financial incentives by engaging multiple payers will leverage the opportunity to transform oncology care across a broader population. During the selection process, CMMI will favor practices that participate with other payers in addition to Medicare. In addition, practices will have to meet certain quality metrics and undergo practice transformation requirements, including: effective use of electronic health records; 24-hour access to practitioners who can consult the patient’s medical record in real time; comprehensive patient care plans; patient navigators; and continuous quality improvement.

While we were pleased to see much of ACCC’s feedback incorporated in the final version, our dialogue with CMS is ongoing. Our members continue to have questions about the benchmarking methodology, specifics on the quality metrics and practice transformation requirements, eligibility to participate in the model, and more. ACCC will continue to seek answers to these questions, and will offer CMS feedback based on member input.

If your practice is interested in participating, or considering participation, we encourage you to submit a non-binding letter of intent to CMS by the deadline of April 23, 2015. We anticipate CMS will continue to provide additional guidance until the application deadline, which is June 18, 2015.

Join us at ACCC’s Annual Meeting CANCERSCAPE on March 17 and hear directly from Ron Kline, MD, Medical Officer with the Center for Medicare and Medicaid Innovation—an author of the Oncology Care Model, as he shares an insider’s perspective on New Payment and Delivery Models in Medicare.