Hospital Outpatient Payment Proposal Has Potential to Undermine Patient Access to Cancer Care

September 29, 2020

In a comment letter to the Centers for Medicare & Medicaid Services (CMS), the Association for Clinical Oncology (ASCO) expressed significant concerns that provisions in the 2021 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule have the potential to undermine access to cancer care for Medicare beneficiaries.

Specifically, ASCO’s comments address:

  • Prior Authorization (PA) – ASCO did not support CMS’ 2020 policy to establish a PA process for certain outpatient department services and opposes CMS’ proposal to further expand this process in 2021—particularly in light of the COVID-19 public health emergency. ASCO is concerned that the expanded use and application of PA may impede patient access to care and increase administrative burden for providers without any clear benefit.
  • 340B Drug Pricing Program – ASCO objects to additional proposed cuts to the 340B program in 2021. ASCO urges CMS to instead implement reforms to the 340B Drug Pricing Program which are needed to ensure the program meets its original intent to support high-quality, equitable care for the uninsured, underinsured, and low-income patients.
  • Inpatient Only (IPO) List – ASCO sees potential value in CMS’ proposal to eliminate the IPO List, which would eliminate site of care requirements, but the Association urges CMS to delay the implementation of this proposal until additional information is available on how the proposal would be implemented and it can be more fully evaluated. In general, however, ASCO supports policies that allow clinical judgement to determine critical medical decisions such as site of care.

Read the full comment letter.   

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