On September 2, 2014, the American Society of Clinical Oncology (ASCO) submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding its proposed rules on the 2015 Medicare Physician Fee Schedule (MPFS)—including the Open Payments Program—and the 2015 Hospital Outpatient Prospective Payment System (HOPPS).
ASCO commented on a number of proposed changes made by CMS that related to misvalued codes, quality measurement and programs, and qualified clinical data registries. Some of ASCO’s recommendations include the following:
- Removing the drug administration services from list of potentially misvalued services.
- Allowing group reporting through qualified clinical data registries (QCDRs),
- Allowing time for ASCO and the cancer community to develop oncology-focused outcome measures for QCDR reporting,
- Expanding the use of specialty-focused measures to promote quality of care in oncology,
- Fully integrating QCDRs within the value-based modifier program,
- Finalizing the proposal to protect small practices from downside risk under the value-based modifier program,
- Delaying mandatory public reporting of QCDR data,
- Refrain from creating an oncology composite score to be posted on Physician Compare based on PQRS measures, and
- Recognizing obesity counseling services provided by oncologists.
The detailed comment letter on the MPFS proposed rule can be viewed here. CMS proposed changes to its Open Payments Program in the MPFS proposed rule. ASCO strongly disagrees with CMS’ proposal to remove the explicit exemption for continuing education under the program. ASCO submitted a separate comment letter specifically addressing concerns with the proposed changes. To read ASCO’s letter to CMS regarding the Open Payments Program, please click here.
ASCO also submitted comments on some of the proposed changes under the HOPPS including reimbursement for cancer drugs, packaging of drugs and drug administration add-on codes, and increasing high-quality, high-value cancer care in outpatient hospital settings. The recommendations include the following:
- Continuing to reimburse for cancer drugs and biologicals at average sales price plus six percent,
- Refrain from the packing the drug administration add-on codes associated with drug administration and from packaging certain drugs, biologicals and radiopharmaceuticals,
- Providing additional payments for certain cancer centers,
- Ensuring cancer patients receive high-quality, high-value care in the outpatient setting,
- Exercising caution when examining the use of various data sets for refining future Medicare payment rates, and
- Allowing greater opportunity for public to comment on APC assignment and status indicators.
ASCO’s comment letter on the HOPPS proposed rule can be viewed in its entirety here.