Decreased Network Adequacy Standards Compromise Patient Access to High-Quality Cancer Care

June 9, 2020

On May 22, the Centers for Medicare & Medicaid Services (CMS) released Part 1 of its final rule outlining changes to the Medicare Advantage (MA) and Medicare Prescription Drug Benefit (Part D) programs for contract year 2021. Due to June 1 bid deadlines for both the MA and Part D 2021 plan years, CMS finalized only a subset of the agency’s proposed policies at this time. CMS will address the remaining proposals later in 2020 for the 2022 plan year.

The Association for Clinical Oncology (ASCO) submitted comments regarding six provisions in the proposed rule: network adequacy, out-of-network telehealth, opioid support efforts, a second “Preferred Specialty” tier, a Real Time Beneficiary Tool, and pharmacy performance measures, only one of which—network adequacy—is addressed in the final rule.

ASCO urged CMS not to finalize proposals that would decrease network adequacy by reducing the percentage of beneficiaries within time and distance standards from 90% to 85% in micro counties and rural counties or to give MA plans a 10 percentage point credit toward the percentage of beneficiaries residing within time and distance standards for certain provider specialty types when the plan contracts with telehealth providers. Despite ASCO’s efforts, CMS finalized both proposals, stating that the COVID-19 pandemic highlighted how important it is to have policies that encourage the widespread availability of telehealth services.

While ASCO supports CMS’ efforts to increase the use of telehealth services, the Association does not believe that such efforts justify reducing network adequacy. ASCO supports network adequacy standards that promote access based on specific patient needs, availability of care and providers, and appropriate utilization of services. People with cancer and survivors require timely access to cancer specialists, facilities, and supportive care. It is imperative that federal standards create a regulatory floor that is robust enough to support the medical needs of all beneficiaries.

ASCO will continue to engage with CMS and support policies aimed at improving network adequacy and the availability of telehealth.

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