The Association for Clinical Oncology (ASCO) submitted comments to the Centers for Medicare & Medicaid Services in response to two cancer-related provisions in the 2022 Medicare Hospital Inpatient Prospective Payment System (IPPS) proposed rule. ASCO’s comments include responses to CMS’ Requests for Information (RFIs) on the transition to digital quality measures and health equity.
ASCO supports CMS’ proposal to maintain the rate-setting methodology finalized in the 2021 IPPS final rule regarding the exclusion of clinical trial cases and cases with standard pharmacy charges less than $373,000 from rate-setting for Medicare Severity Diagnosis Related Group (MS-DRG) 18 as these cases do not reflect the actual hospital costs for providing chimeric antigen receptor T-cell (CAR-T) therapy. ASCO applauds CMS for establishing the MS-DRG for CAR-T; however, should CMS include these cases without adjusting the relative weight, the resulting reimbursement rate for the MS-DRG would be insufficient to cover the cost of providing the therapy, jeopardizing cancer patient access to these potentially life-saving treatments.
As the steward of the Oncology: Plan of Care for Pain – (NQF #0383) quality measure, ASCO requests CMS not remove this measure from the PPS-Exempt Cancer Hospital Quality Reporting (PCHQR) program beginning with the FY 2024 program year as proposed. ASCO also urges CMS to re-introduce the Oncology: Pain Intensity Quantified – (NQF #0384) measure into the program. The management of all pain, not just moderate to severe pain, is an integral part of high-quality cancer care and should be measured. Data from these two measures will continue to offer actionable performance data to clinicians to ensure the delivery of high-quality cancer care.
CMS aims to move fully to digital quality measurement in its quality reporting and value-based purchasing programs by 2025 while also updating and aligning quality measures across the different reporting programs. ASCO submitted responses to an RFI accompanying the proposed rule seeking comment on a four-stage plan to transition CMS’ quality measurement enterprise to fully digital by 2025. ASCO offered technically specific and detailed responses to guide CMS’ implementation as the Association believes that access to near real-time quality measure scores would benefit oncology practices. However, ASCO has reservations that purely digital quality measurement is possible, even by 2025, without the wholesale requirement of the use of data standards developed for oncology, such as mCODE.
CMS also released an RFI looking for stakeholder input on how the agency can improve data collection and measurement to help advance health equity in Medicare. ASCO comments included a response supporting the collection of demographic elements and use of relevant data for quality improvement. ASCO believes measures of race, ethnicity, sexual orientation, and gender identity should be self-reported and collected in all clinical settings. Health equity and cancer disparities have long been a focus in ASCO’s programs and policy work, and we look forward to working closely with CMS to ensure equitable access to high-quality cancer care for Medicare beneficiaries.
Read the full comment letter.
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