In a letter to the Centers for Medicare & Medicaid Services (CMS), the Association for Clinical Oncology (ASCO) provides comments on provisions in the 2022 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP) proposed rule that would impact cancer care for Medicare beneficiaries. The letter also offers perspective on CMS’ four-stage plan to transition CMS’ quality measurement enterprise to being fully digital by 2025 and how the agency can improve data collection and measurement to help advance health equity in the Medicare program.
ASCO’s extensive comments offer the Association’s perspective in a number of areas, including reimbursement, telehealth, and Appropriate Use Criteria as part of the commitment to working with CMS to help ensure access to high-quality, equitable cancer care for all patients no matter who they are or where they live.
In 2022, oncology practitioners are expected to absorb alarming decreases in reimbursement because of four primary factors: 1) the 3.75% decrease to the PFS conversion factor (CF), 2) the reinstatement of Medicare sequestration, 3) statutory sequestration, and 4) decreases in Relative Value Units (RVU) for oncology services. ASCO calls on CMS to work with Congress to address these cuts to reimbursement to preserve patient access to high-quality, equitable cancer care and to maintain physician practice health and viability.
ASCO’s comments are summarized below:
Medicare Physician Fee Schedule
- ASCO strongly urges CMS work with Congress to address the looming cuts to reimbursement resulting from the reduced conversion factor, the expiration of the Medicare sequestration moratorium, and the statutory sequestration set to take effect in January 2022.
- ASCO supports CMS’ proposal to update labor prices and encourages CMS to update practice expense inputs on a more frequent basis; however, we strongly urge CMS to delay implementation of the updated labor prices until CMS can work with ASCO to establish rates for RN/OCN clinical labor and until Congress can address a permanent legislative fix to budget neutrality.
- ASCO supports CMS’ proposal to extend coverage of Category 3 telehealth services through the end of CY 2023; however, we strongly urge CMS to add office/outpatient services for telephone evaluation and management to the Category 3 list.
- ASCO strongly supports CMS’ proposal to permanently adopt coding and payment for audio-only virtual check-in code G2252 and to continue to expand coverage for all modes of delivery of telemedicine.
- ASCO supports regulatory updates to waive co-insurance and simultaneously to increase Medicare payments for screening colonoscopies and sigmoidoscopies when they become a diagnostic procedure.
- ASCO supports delaying the e-prescribing of controlled substances compliance requirement until January 1, 2023.
- ASCO supports CMS’ proposal to waive e-prescribing requirements for a prescription issued when the practitioner and dispensing pharmacy are the same entity.
- ASCO supports CMS’ proposal to waive e-prescribing requirements in cases of recognized emergencies and extraordinary circumstances such as natural disasters, environmental hazards, or a pandemic, and in cases of prescribers facing extraordinary circumstances preventing them from electronically prescribing a controlled substance such as lack of broadband.
- ASCO urges CMS to list the drugs approved through the 505(b)(2) pathway that would be mapped to a multiple source code and to state the financial impact this proposal would have on the Medicare program.
- ASCO supports CMS’ proposal to delay enforcement of the Appropriate Use Criteria (AUC) program, offering practitioners and practices relief from financial and administrative burdens.
Quality Payment Program
- ASCO does not support CMS’ proposal to sunset the traditional Merit-based Incentive Payment System (MIPS) in favor of the newly created MIPS Value Pathways (MVPs) in 2028. There is no statutory requirement for MVPs, and CMS should not implement it until there has been successful uptake and use by clinicians. Only by examining clinicians’ use of MVPs can CMS make an informed proposal on the eventual sunsetting of traditional MIPS.
- As the steward of the Oncology: Plan of Care for Pain (NQF #0383) measure, ASCO strongly urges CMS not to remove this measure from the MIPS program beginning with the 2022 performance year as proposed.
- ASCO urges CMS to consider maintaining the current threshold for the 2022 performance year, rather than moving ahead with increasing the threshold every year as though the program were proceeding the pandemic.
- ASCO supports CMS’ proposal to no longer require an application from small practices for the small practice hardship exception and reweighting of performance categories.
- ASCO does not support the inclusion of Part D prescription drug costs in MIPS cost measures and urges CMS to develop cost measures with input from national specialty societies and other interested stakeholders.
Read the full comment letter.
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