ASCO submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to a proposed rule that would loosen state reporting requirements and potentially threaten access to cancer care for Medicaid beneficiaries. ASCO believes all patients should have access to high-quality, high-value cancer care and is concerned that CMS’ proposal would jeopardize that access.
CMS is currently required to establish reimbursement rates that are sufficient to ensure that Medicaid beneficiaries have the same access to care and services as the general population in their area. To that end, ASCO believes that CMS has a duty to ensure states are able to determine and demonstrate that they meet federal access requirements, as well as to put forth a transparent process for managed care plans to do the same.
CMS’ proposal would, among other provisions, rescind the current regulatory framework requirement for Access Monitoring and Review Plans (AMRPs). AMRPs require states to analyze data to determine if patients have sufficient access to covered services provided under fee-for-service. ASCO is concerned that removing this requirement without first establishing a comprehensive monitoring and reporting system that enables input from providers, patients, and other key stakeholders, could weaken access to high-quality, high-value care for people with cancer.
“ASCO strongly urges state and federal policymakers to focus on the impact that any changes to Medicaid policy could have on patients with cancer,” said ASCO President Howard A. “Skip” Burris III, MD, FACP, FASCO. “Therefore, we request that CMS develop a consistent set of metrics and measures along with appropriate feedback mechanisms that will ensure that all states can consistently and transparently evaluate access to care in light of potential payment changes.”
ASCO’s comments also make specific recommendations that CMS should:
- Ensure that Medicaid beneficiaries have access to the basic elements of health coverage essential to contemporary cancer treatment, including patient access to clinical trials, oral anticancer drugs, cancer screening and genetic testing, and a value-based system that rewards quality of care.
- Set minimum thresholds for Medicaid access to care and require states to assess access to care to ensure that Medicaid beneficiaries with a cancer diagnosis are able to access high-quality oncology care in a timely fashion. Oncologists and oncology subspecialists should be explicitly added to the types of specialists that are subject to ongoing state access reviews.
- Continue to assess the adequacy of payments made to providers to ensure that Medicaid rates are consistent with “efficiency, economy and quality of care,” and that physician reimbursement is sufficient to allow oncologists to participate in the Medicaid program.
“Cancer patients and survivors are a particularly vulnerable subset of the Medicaid population. They require timely access to cancer specialists, facilities, and supportive care,” said Dr. Burris. “It is imperative that federal standards create a regulatory floor that is robust enough to support the medical needs of all Medicaid beneficiaries independent of their state of residence.”
ASCO’s comments were informed by the society’s 2014 policy statement on Medicaid reform, which established principles to ensure access to high-quality and high-value cancer care for all Medicaid beneficiaries. The society urges CMS to ensure access to all elements of cancer treatment for all patients with Medicaid.