ASCO voiced its strong opposition to the proposed Medicare Part B demonstration project in comments submitted for the June 28 U.S. Senate Finance Committee hearing, "Examining the Proposed Medicare Part B Drug Demonstration." ASCO underscored the urgent need to advance a fairer and more responsible payment system for oncology than what is offered in the ill-advised proposal from the Centers for Medicare & Medicaid Services (CMS)—calling on CMS to withdraw the proposal or urging Congress to intervene before this flawed experiment irreparably harms the cancer care delivery system.
"The assumptions and emphasis of the Part B Drug Payment model are misplaced," said ASCO President Daniel F. Hayes, MD, FASCO, in the statement. "If CMS’s goal is to lower drug prices, this demonstration is not designed to achieve that outcome. Rather, the proposed demonstration places doctors and Medicare beneficiaries in the position of making impossible choices without directly addressing the underlying problem of high drug prices."
ASCO's specific concerns regarding the Part B demo include:
- An Experiment on Patients Without Safeguards – ASCO asserts that Phase 1 of the demo is essentially a mandatory experiment on seniors with cancer, but without accepted patient safeguards in place. Patients cannot opt out of the demo and receive no informed consent, as is mandatory in ethical clinical research. Further, there is also no way to monitor potential adverse consequences in real-time.
- Demo Would Likely Increase “Underwater” Drugs – The Centers for Medicare & Medicaid Services (CMS) based the demo on the faulty assumption that a Part B drug reimbursement rate of average sales price (ASP) plus 2.5 percent will cover drug acquisition costs. The 2 percent Medicare sequestration cut will apply to Part B drugs under the demo and reduce the real-world rate to ASP plus 0.86 percent with an add-onf $16.53 per drug per day—a rate that is effectively “underwater" for many cancer treatments. In other words, CMS would likely reimburse practices for less than the acquisition cost of many oncology drugs—possibly forcing many independent oncology practices to send their Medicare patients to other higher-cost facilities for treatment.
- Shifting Site of Care Problematic – The Part B demo would remove resources from practices as they prepare for changes under the Medicare Access and Chip Reauthorization Act (MACRA). This could disrupt the site of care for Medicare patients with cancer, work against the goals of MACRA, and increase the costs to the system overall.
- Part B Demo Versus the Oncology Care Model – The proposed rule also runs counter to the care improvement efforts embedded in CMS’s own Oncology Care Model (OCM). Medicare currently offers little or no payment for most of the care cancer patients need: treatment planning, patient education, patient and family counseling, coordination of care, mental health and other emotional support services, quality improvement, patient navigator services, triage nurse services, genetic counseling services, financial counseling services, nutrition counseling and dieticians, and community outreach. While CMS appears to have acknowledged this payment gap for such services by adding a monthly payment into OCM specifically designed to support care transformation, these are the very services that will be put at risk under the Part B demo.
ASCO has also been working on the transition from volume-based care to value-based. The society estimates that its Patient Centered Oncology Payment (PCOP) model, an oncology-specific payment system will decrease costs, while providing the resources oncology practices need to provide high-quality, high-value cancer care, by matching payment more closely with actual care provided. According to ASCO, PCOP will allow practices to plan cancer care in a way that helps patients avoid expensive hospitalizations and unnecessary tests and treatments.
The Part B Model does not take advantage of promising work that has the potential to yield comprehensive reforms and achieve CMS’s stated goals. In addition to developing PCOP, ASCO has worked for more than a decade to support oncology practices in the delivery of high-quality, high-value oncology care, through its Clinical Oncology Pathways statement, CancerLinQ, the Quality Oncology Practice Initiative (QOPI), and the ASCO Value Framework.
ASCO believes its work can seed a comprehensive healthcare delivery and payment system that will support high-quality, high-value oncology for all individuals facing life-threatening cancers. The society hopes to work closely with CMS and other stakeholders to address the complex issues involved in transforming cancer care in the United States.
“We are hopeful that CMS will realize that this proposal moves payment policy in the wrong direction and is counter to CMS’ more constructive efforts,” said Dr. Hayes in the ASCO statement. “However, if they continue to move forward, we urge Congress to intervene to prevent permanent damage to the oncology infrastructure.”
Read ASCO's full statement.