In a letter to the Centers for Medicare & Medicaid Services (CMS), ASCO President Howard A. “Skip” Burris III, MD, FACP, FASCO, commented on provisions in the proposed 2020 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP) proposed rule that would impact cancer care for Medicare beneficiaries.
“ASCO recognizes the significant changes CMS is continuing to make to improve payment policies for Medicare services and appreciates CMS’ willingness to engage stakeholders in discussions of proposed changes to both the Physician Fee Schedule and Quality Payment Program policies,” writes Dr. Burris. “However, ASCO has concerns regarding some of the policies proposed by CMS for calendar years (CYs) 2020 and 2021.”
The extensive comments offer ASCO’s perspective in a number of areas as part of the society’s commitment to working with CMS to help ensure access to high-quality, high-value cancer care for all patients no matter who they are or where they live.
The Proposed 2020 MPFS
- Coding and Reimbursement for Evaluation & Management (E&M) Visits – ASCO’s comments focus on ensuring E&M codes adequately reflect all services that comprise high-quality cancer care. Specifically, ASCO recommends that CMS finalize its proposal to reverse some of its 2019 changes to the coding and payment structure for E&M services, and to align E&M coding and payment with changes adopted by the American Medical Association’s CPT Editorial Panel for E&M services. The society also urges CMS to accept payment recommendations from the American Medical Association’s (AMA) Specialty Society RVS Update Committee (RUC) for the office/outpatient E&M visit codes for CY 2021 and the new add-on CPT code for prolonged service time.
- Care Management Codes – ASCO supports CMS’ efforts to expand the availability of the chronic (complex) care management and transitional care management codes, as well as the agency’s proposal to establish new “principal care management” codes that would apply to patients with one complex medical condition. However, ASCO urges CMS to work toward alignment of these codes between CMS and private payers.
Updates to the QPP
- Changes to Merit-Based Incentive Payment System (MIPS) Cost Measures – ASCO opposes CMS-proposed changes to MIPS cost measures that would continue to include the cost of drugs in overall resource use. ASCO has consistently objected to the inclusion of drugs costs in these measures as they unfairly penalize physicians who have no control over drug prices. ASCO strongly urges CMS to add the oncology specialties to the proposed list of 56 non-attributed specialties that would be exempted from the such measures.
- Quality Measures and Qualified Clinical Data Registry (QCDR) Criteria – ASCO’s comments focus on ensuring that changes to quality reporting measures and QCDR requirements under MIPS truly foster high-quality cancer care. To that end, ASCO weighed in on proposed changes to MIPS’ cancer care-related quality measures and updates to Qualified Clinical Data Registry (QCDR) approval criteria. ASCO strongly urges CMS not to implement a proposal that—starting with the 2021 performance period—would require QCDRs to have quality measures tested at the clinician level before they can be considered for use in MIPS. ASCO opposes this provision due to the burdens that would likely be imposed on QCDR provider and physicians given the varying cost and complexity of testing QCDR measures
- High-Quality Value-Based Pathways – ASCO continues to urge CMS to integrate high-quality value-based clinical pathways into MIPS to assess quality and value for clinicians who use expensive drugs with prices they do not control. ASCO expressed initial support for the agency’s proposal to revamp MIPS by establishing the MIPS Value Pathway (MVP) framework and provided multiple suggestions in response to the agency’s request for information. ASCO did, however, urge CMS to ensure the voluntary nature of MVP reporting, to establish a reasonable timeframe for pilot implementation, and to work closely with stakeholders such as medical specialty societies in MVP development. By 2021, CMS is aiming to move away from the current MIPS structure (reporting on activities and measures in four performance categories) by transitioning to the MVP framework with a unified set of measures and activities centered around a specific condition or specialty along with a set of population health measures. ASCO has extensively examined oncology clinical pathways and is eager to work with CMS as its proposals continue to take shape.
“As health care payment models continue to advance, private insurers have already embraced the use of oncology clinical pathways that incorporate both evolving scientific evidence and considerations of cost and value,” writes Dr. Burris. “We have encouraged the Medicare program to adopt high-quality value-based pathways as a mechanism to assure the highest quality and most appropriate care for Medicare patients facing a cancer diagnosis.”