ASCO submitted comments to the Centers for Medicare & Medicaid Services (CMS) on proposed changes to Medicare Advantage and Medicare Part D prescription plans for 2019. The comments included recommendations for updating prior authorization requirements as well as feedback on policies to address the national opioid epidemic.
In the comment letter, ASCO President Bruce E. Johnson, MD, FASCO, urged CMS to further consider the impact of Part D payer business practices on patients with cancer. Oral anticancer drugs, covered through Medicare Part D by Medicare Advantage Organizations (MAO) and Part D Plan Sponsors, are increasingly used in cancer care. The society raised concerns regarding increasing intervention by MAOs and plan sponsors in medical decision making, as well as excessive administrative burdens imposed by payer utilization management policies.
The comments pointed to ASCO’s policy statement on utilization management for cancer drug therapies, released in 2017, which provides recommendations for streamlining utilization management and prior authorization processes to ensure that policies promote, rather than hinder, patient access to high-quality, high-value cancer care. In addition to proposing tactics to address payer business practices that impede timely access to appropriate treatments, the comments also noted the potential use of clinical pathways as a mechanism for ensuring appropriate prescribing practices and medication selection.
ASCO also applauded CMS for its efforts to ensure access to medically necessary palliative care for patients with cancer, expressing support for the continued exemption of patients with cancer from Part D utilization policies for opioids. The comments reaffirmed the society’s support for the Comprehensive Addiction and Recovery Act (CARA) and the exclusion of cancer patients from CARA’s drug management program for at-risk patients. “The Agency’s decision to exempt cancer patients from the program recognizes their unique needs and will help insure their immediate and timely access to medically necessary pain relief during all stages of treatment,” said Dr. Johnson.