340B Needs Reforms, Not Cuts, to Improve Low-Income Americans' Access to Care

September 22, 2021

In comments to the Centers for Medicare & Medicaid Services (CMS), the Association for Clinical Oncology (ASCO) expressed significant concerns that several provisions in the 2022 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule have the potential to undermine access to cancer care for Medicare beneficiaries. ASCO does, however, support some updates CMS has proposed for calendar year 2022.

Key points in ASCO’s comments include:

  • ASCO continues to object to CMS’ policy that sets a differential Medicare payment rate for separately covered outpatient drugs purchased under the 340B drug pricing program. ASCO urges CMS to instead implement reforms to the program, which are needed to ensure it meets its original intent to support high-quality care for the uninsured, underinsured, and low-income patients.
  • ASCO strongly urges CMS to collaborate closely with the American Society of Radiation Oncology (ASTRO) on implementation of the Radiation Oncology Model and to implement the recommendations ASTRO has outlined, including establishing rate stability through the application of a discount factor set at 3% or less.
  • ASCO supports the agency’s decision to halt the elimination of the Inpatient Only (IPO) List. Prior to implementing any changes or modifications to the IPO List, ASCO urges the agency to fully evaluate the impact of any further proposed changes.
  • ASCO thanks CMS for not expanding the hospital outpatient prior authorization (PA) process in this rulemaking cycle. The Association urges the agency to review the current program to assess its impact on utilization, patient access to care, and the administrative burden it generates. ASCO did not support the CMS policy in 2020 to establish the program or its expansion in 2021.

Read the full comment letter.

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