In Comments to CMS, ASCO Outlines Recommendations on Proposed QPP Rule

August 22, 2017

ASCO submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its proposed rule outlining changes to the Quality Payment Program (QPP) for 2018. In a letter to CMS Administrator Seema Verma, ASCO President Bruce E. Johnson, MD, FASCO, made recommendations regarding the two major paths for physician reimbursement within QPP, the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).

Cancer Cost Assessment and Payment Adjustments Under MIPS

The proposed QPP rule includes a provision that could make certain Medicare Part B drug reimbursements subject to MIPS adjustments, which would seriously distort the magnitude of MIPS penalties and bonuses far beyond anything Congress intended when drafting the Medicare Access and CHIP Reauthorization Act (MACRA)—which established the QPP.

ASCO’s data show that the median financial penalty for oncology practices under the proposal would range from 13.7% - 22.9%—well beyond the CMS-envisioned 4% penalty. In its comments, ASCO urges CMS to refrain from implementing such a policy at any point in time.

To guide CMS in establishing a fair and accurate assessment of cancer costs under MIPS, while promoting the interests of Medicare beneficiaries and the Medicare program as a whole, ASCO offers the following principles:

  • Oncology Clinical Pathways: CMS should measure adherence to high-quality oncology clinical pathways as a quality metric rather than using raw, unadjusted oncology cost data for anticancer drugs as a component of the resource category for medical oncology under MIPS.
  • Oncology Drugs: If CMS proceeds with its proposal to use cost data from Medicare claims as a measure of cost performance in MIPS, the costs of Part B and Part D drugs must be excluded or adequately risk-adjusted. 
  • Oncology Episodes of Care: ASCO supports efforts to develop oncology-specific episodes for evaluating resource use under MIPS. 

Alternative Payment Models

ASCO strongly urges the Center for Medicare and Medicaid Innovation (CMMI)—a division of CMS—to implement multiple oncology-focused APMs, including ASCO’s Patient-Centered Oncology Payment (PCOP) model. Testing multiple oncology-specific APMs is necessary to meet the needs of a diverse Medicare population and to allow oncologists to evaluate models and choose the best approach for their patients and practices.

“The Oncology Care Model, which is currently in place through the Innovation Center, is certainly one such approach that has drawn participation from a large number of practices,” wrote Dr. Johnson in ASCO’s comment letter. “However, as illustrated throughout this proposed rule, there is a deep need for testing multiple creative solutions for defining episodes, and dealing with specialty drug costs in the rapidly changing environment of personalized cancer care. It would be a wasted opportunity if only one model were allowed to be tested.”   

Read ASCO’s full comment letter.

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