In Comments to CMS, ASCO Responds to Final Quality Payment Program Rule

January 2, 2018

ASCO submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the agency’s rule finalizing changes to the Quality Payment Program (QPP) in 2018. ASCO commends CMS for providing relief to physicians impacted by hurricanes in 2017, but urges the agency to remove Part B reimbursement from payment adjustments under the Merit-Based Incentive Payment System (MIPS) and to reconsider the weighting of ASCO quality programs in the MIPS Improvement Activities (IA) category.

2017 Hurricane Relief

ASCO is pleased that CMS established the “automatic extreme and uncontrollable circumstance policy” to provide relief to individual physicians impacted by hurricanes Harvey, Irma, and Maria. ASCO urges CMS to extend the policy to group practices, especially small group practices with 15 or fewer eligible clinicians.

The society also urges CMS to promote access to cancer care for patients that have been displaced by any of the 2017 hurricanes, particularly victims of Hurricane Maria from Puerto Rico who have taken shelter on the U.S. mainland. ASCO urges CMS to ensure that these patients continue to have immediate access to cancer care while they are displaced from their homes.

Assessing Cancer Costs and Evaluating ASCO Quality Programs Under MIPS

ASCO urges CMS to reverse its plan to include Part B drug reimbursement in the MIPS payment adjustment. In ASCO’s view, the provision distorts the magnitude of MIPS penalties and bonuses far beyond what Congress intended when drafting the Medicare Access and CHIP Reauthorization Act (MACRA)—which established QPP. ASCO’s data show that the median financial penalty for oncology practices under the provision would range from 13.7% - 22.9%, well beyond the Congress-envisioned 4% penalty, and leave some oncology practices with no choice but to close their doors. ASCO suggests that CMS instead measure adherence to high-quality clinical pathways to determine cost efficiency performance.

The society also urges CMS to reevaluate ASCO’s Quality Oncology Practice Initiative (QOPI™) Certification Program (QCP) and Quality Training Program (QTP) for the Improvement Activities category of MIPS. Both programs have been weighted as “medium,” which ASCO believes vastly underestimates the amount of time and resources required for successful completion of either program. ASCO asserts that a fuller understanding of these programs would result in a fairer weighting that more accurately reflects the value these programs provide patients. The society would welcome the opportunity to discuss the programs in more detail with CMS.

Read ASCO’s full comment letter.

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