Value-Based Approaches Are Focus of ASCO Comments on Administration’s Blueprint to Lower Drug Prices

July 17, 2018

ASCO submitted a response to the Request for Information (RFI) that was included in the Trump Administration's “blueprint to lower drug prices and reduce out-of-pocket costs.” In a letter to Secretary of the U.S. Department Health and Human Services (HHS) Alex Azar, ASCO recommends a value-based approach to address rising drug costs and makes specific recommendations regarding the 340B Drug Pricing Program, reviving the Competitive Acquisition Program (CAP), moving drugs from Medicare Part B to Part D, and site neutrality proposals. 

“In recent years, there has been tremendous progress in development of new classes of drugs that have greatly improved outcomes for patients with certain cancers,” said ASCO President Monica M. Bertagnolli, MD, FACS, FASCO, in the ASCO letter to HHS. “However, high drug prices are a prominent factor in eroding access to care for patients, particularly many cancer patients.”

ASCO Recommendations Regarding Relevant Programs and Proposals in the Blueprint

ASCO’s comments urge policymakers to replace the Disproportionate Share Hospital (DSH) adjustment percentage—a 340B eligibility metric for hospitals—with a metric that more appropriately reflects the original intent of the 340B program to serve low-income patients. ASCO also asserts that standalone community oncology practices should be recognized as 340B-eligible providers if they have demonstrated records of providing cancer care to uninsured, underinsured, and indigent patients.

ASCO opposes moving chemotherapy and other oncology supportive care drugs from Medicare Part B to Part D, as proposed in the blueprint, citing the potential for patients to experience higher out-of-pocket costs or loss of coverage. Approximately 9 million Part B beneficiaries do not have Part D coverage and transitioning cancer drugs to Part D could dramatically undermine access to care for these beneficiaries. 

Another concern with shifting oncology drugs to Part D is the potential to magnify the impact of pharmacy benefit managers (PBM) on patient care. ASCO members already report treatment delays, medication switching without physician notification, and unnecessary administrative burdens imposed by PBMs policies—issues not seen in Part B.

ASCO also opposes removing any resources from the cancer care delivery system to reconcile payment differences across care settings. ASCO has long called for comprehensive payment reform instead of relying on site neutrality, which cuts reimbursement in a piecemeal fashion. ASCO urges HHS to recognize that the current reimbursement system fails to recognize all the services needed to provide high-quality cancer care. 

Regarding the Administration’s proposal to revive CAP, ASCO asserts that to successfully lower the cost of drugs, a revised CAP must be significantly redesigned to address concerns about patient care and administrative burdens that arose when CAP was initially implemented in 2006. 

Incorporating Clinical Pathways and ASCO’s Payment Reform Model

To truly address rising drug costs and the need for physician payment reform in the United States, ASCO supports value-based initiatives that protect the interests of patients with cancer. Specifically, ASCO’s comments outline how high-quality oncology clinical pathways and the society’s own alternative payment model, the Patient-Centered Oncology Payment (PCOP) model, can help contain the cost of cancer treatment while promoting high-quality patient care.

High-quality clinical pathways ensure the consistent and coordinated delivery of evidence-based care across the oncology treatment team, and PCOP better aligns cancer care services with physician reimbursement to offer stable and predictable payments while allowing individual practices to use their resources in the way that best suits their specific practice environment and patient population.

“By providing practices flexibility—and the resources needed for comprehensive patient management, including avoidance of unplanned ER visits and hospitalizations, the Medicare program would promote value by improving the quality of care and reducing costs by decreasing unplanned acute care and improving the management of end-of-life care,” writes Dr. Bertagnolli.

Read the full Letter to Secretary Azar.

ASCO will continue to promote its alternative payment model and work with HHS toward a sustainable physician reimbursement system that promotes patient access to high-quality cancer care. Stay tuned to ASCO in Action for updates on cancer drug pricing policies and other breaking cancer policy news.