• Facebook
  • Twitter
  • Youtube
  • Instagram
  • LinkedIn
  • Rss
  • Store
  • Donate
NCCS - National Coalition for Cancer Survivorship
  • About
    • Our Mission
    • Our History
    • The 1986 Club
    • Our Team
      • Policy Advisors
    • Employment
    • Partnerships
    • Financial Information
  • Policy
    • Quality Cancer Care
    • Access to Care
    • Health Equity
    • Redefining Functional Status (RFS)
    • 2022 State of Cancer Survivorship Survey
    • 2021 State of Cancer Survivorship Survey
    • 2020 State of Cancer Survivorship Survey
    • Cancer Care Planning and Communications Act (CCPCA)
  • Get Involved
    • What is Advocacy?
    • Cancer Policy and Advocacy Team (CPAT)
    • Survivorship Champions
    • Subscribe to NCCS Updates
    • Elevating Survivorship
    • Survivor Stories
    • Cancerversary
    • State-Based Cancer Advocacy
  • Resources
    • COVID-19 Resources for Cancer Survivors
    • Survivorship Checklist
    • Cancer Survival Toolbox
    • Telehealth
    • Publications
      • Talking With Your Doctor
      • Self Advocacy
      • Employment Rights
      • Remaining Hopeful
    • Cancer Convos Podcast
    • Taking Charge of Your Care
    • Care Planning for Cancer Survivors
    • Tools For Care Providers
    • Order Our Resources
  • News
  • Events
    • Ellen L. Stovall Award
      • Nominations
      • 2022 Winners
      • Awardees
      • Reception and Sponsorship
    • Cancer Policy Roundtable (CPR)
      • Fall 2022 CPR
      • Spring 2022 CPR
      • Fall 2021 CPR
      • Spring 2021 CPR
      • Fall 2020 CPR
      • Spring 2020 CPR
    • Cancer Policy and Advocacy Team (CPAT) Virtual Symposium 2022
    • 2022 State of Survivorship Survey Results
    • Webinars
  • Contact Us
  • Search
  • Menu Menu
  • 0Shopping Cart

Your generous year-end donation will be matched $1 for $1    DONATE

Fotolia 23428619 S e1461260836640

NCCS Comments on CMS’s Proposed Revisions to the 2017 Physician Fee Schedule

September 7, 2016/in Cancer News, Cancer Policy Blog, CMS, NCCS News, Policy Comments Access to Care, Care Planning, Health Care Coverage, Payment Reform, Quality Cancer Care, Survivorship Care NCCS News, Policy Comments /by actualize

NCCS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed revisions to the 2017 Physician Fee Schedule. Our comments noted our support for the Oncology Care Model, but acknowledged that only a minority of cancer care providers and cancer patients will be part of this model. Therefore, changes to the fee-for-service system to foster patient-centeredness are needed to improve quality of cancer care for Medicare beneficiaries.

We supported some specific changes that CMS proposed to recognize the time spent outside the in-person office visit and to reduce the administrative burden associated with using chronic care management codes. We believe that in these proposals, CMS has balanced the needs of patients with the burden on providers, and that increased utilization of the chronic care management codes will enhance care planning and care management for Medicare beneficiaries with multiple chronic conditions, including many cancer survivors.

Additionally, NCCS supported the comments submitted by the Cancer Leadership Council, which made similar points about the need to reduce barriers to providing care management services and using the codes that would reimburse for these services.

Our full comment letter is reprinted below.

PDF Download: NCCS Comments to CMS on the proposed 2017 Physician Fee Schedule »


NCCS logo blue-yellow sm

September 6, 2016

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201

Re: CMS-1654-P, Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2017

Dear Mr. Slavitt:

The National Coalition for Cancer Survivorship (NCCS) is a national organization representing survivors of all types of cancer in efforts to foster patient-centered cancer care, including in the medical home setting. We have focused on several critical elements of the cancer care system in our efforts to improve the overall quality of care. We believe that patients should begin their cancer care experience with a shared decision-making process. We also consider patient-centeredness a core element of quality care.

We have lent our strong support to the Oncology Care Model demonstration project, which holds promise for the coordination of care across episodes of care as well as coordination among all cancer care providers. We are especially pleased that the Oncology Care Model includes cancer care planning as one of the elements of care that Oncology Care Model practices must include in their medical home model. Care planning as defined in the Oncology Care Model will encourage patients to consider the goals of their treatment and will foster shared decision-making. These elements of the care process hold promise of improving the “patient-centeredness” of cancer care. For all of these reasons, we believe Oncology Care Model is an important test of the medical home in cancer care. We look forward to its implementation and to evaluation of care that is provided in the model.

Despite our enthusiasm about the Oncology Care Model and the lessons that may be derived from this demonstration project and then replicated, we realize that only a minority of cancer care providers and a minority of cancer patients will be part of this model. We would like to see access to cancer care planning and coordination for patients whose care is reimbursed through the fee-for-service system. These services, as we have stressed above, are critical to fostering patient-centeredness. As a result, we have for years recommended that a new Medicare service for cancer care planning be established. We have offered that recommendation through comments on Physician Fee Schedule updates for previous calendar years and have pursued other actions to establish such a service for cancer patients.

We have in past years expressed our support for establishment of the Transitional Care Management Code, the Chronic Care Management Code, and the Advance Care Planning Code, because these new codes represent important steps toward more effective care management and the delivery of patient-centered care. At the same time, we have urged the establishment of a code that would be specifically targeted to cancer patients and would ensure cancer care planning and management.

Cancer patients would benefit from care planning and management across the continuum of care. However, we note two occasions when these services might be provided with the potential for substantially enhancing the quality of care. After diagnosis and at the time of treatment decision-making, care planning and management services can help to ensure that cancer patients with additional chronic conditions have access to well-planned and coordinated care – care that is coordinated through the episode of cancer care and care that is managed across all medical subspecialists providing care. At the completion of active treatment, cancer patients with additional chronic conditions face substantial challenges in the monitoring of their health status and the coordination of multi-disciplinary care. Cancer survivors may face risks of a wide range of possible late and long-term effects related to their cancer and care treatment, in addition to the challenges of other chronic conditions. Timely follow-up care may be necessary to address these late and long-term effects and ensure high quality of life for cancer survivors after their cancer treatment.

Ensuring the appropriate utilization of the chronic care management codes holds promise of boosting the overall quality of cancer care for Medicare beneficiaries.

Improving Payment Accuracy for Care Management and Patient-Centered Services

In the proposed rule, the Centers for Medicare & Medicaid Services (CMS) stated:

“In recent years, we have undertaken ongoing efforts to support primary care and patient-centered care management within the PFS as part of HHS’ broader efforts to achieve better care, smarter spending and healthier people through delivery system reform.”
We support, with some reservations, the following provisions of the proposed rule that seek to improve delivery of patient-centered care.

  • Recognizing CPT code 99358, for prolonged evaluation and management service before and/or after direct patient care, first hour, and CPT code 99359, prolonged evaluation and management service before and/or after direct patient care, each additional 30 minutes. We believe that these codes, which seek to recognize the resource costs related to time spent outside the in-person office visit to care for Medicare patients, may improve cancer treatment and cancer survivorship planning and management. We hope that these codes will be utilized by providers who are spending substantial time outside the in-person office visit related to the planning and management of cancer care. We have received feedback from cancer care providers that the resources necessary to plan active treatment and to map out survivorship care options are not adequately recognized in existing codes.

  • Reducing the administrative burden associating with the chronic care management codes to remove barriers to billing for these services. Although, as noted above, we saw promise in the chronic care codes in connection with cancer treatment planning and survivorship care, we understand that they have not been widely utilized by providers of cancer care. The feedback that we have received is consistent with the conclusions of CMS regarding possible underutilization of chronic care management services, based on the number of eligible Medicare beneficiaries.

    We understand that the original standards for utilization of the chronic care codes were intended to ensure the proper utilization of the codes and were also intended to offer certain protections to beneficiaries receiving chronic care management services. However, if the standards for the codes are resulting in underutilization, cancer patients are not seeing any benefits from the codes.

    We would not typically support the changes in the consent requirements, the 24/7 electronic access to care plans, or the reliance on fax transmission of care plans to patients. However, in this situation, we think that CMS has balanced the needs of patients against the burden on providers seeking to use the chronic care codes. If this balancing of interests achieves greater utilization of the chronic care codes – including for cancer patients and survivors – it will have been a patient-centered revision of the standards for the codes. We encourage CMS to carefully monitor the utilization of the codes and especially to ensure that that there are conversations between provider and patient supporting patient consent for chronic care services. Patient consent is important because of the cost-sharing requirements associated with chronic care services.

  • Establishing a new G-Code to improve payment for visits that are considered initiating visits for chronic care management services. We believe there is some promise that the G-Code for initiating services will eliminate the potential for the initiating visit requirement to impede access to chronic care management.

We appreciate the opportunity to comment on the calendar year 2017 Physician Fee Schedule update proposal. We commend the efforts of CMS to enhance care planning and management for Medicare beneficiaries, including those with multiple chronic conditions.

Sincerely,
Shelley Signature
Shelley Fuld Nasso, MPP
Chief Executive Officer

# # #

Read more NCCS Policy Comments »


Tags: cancer care, care planning, CMS, Medicare, Oncology Care Model, patient first, payment reform, policy comments
Share this entry
  • Share on Facebook
  • Share on Twitter
  • Share on WhatsApp
  • Share on LinkedIn
https://canceradvocacy.org/wp-content/uploads/2014/07/Fotolia_23428619_S-e1461260836640.jpg 515 1030 actualize https://canceradvocacy.org/wp-content/uploads/2020/06/NCCA-Logo.png actualize2016-09-07 11:55:012016-09-07 11:55:01NCCS Comments on CMS’s Proposed Revisions to the 2017 Physician Fee Schedule

Latest News

NCCS Urges President Biden and Congress to Support and Protect Medicaid

March 24, 2023
This week, NCCS joined with more than 30 patient advocacy organizations as part of the Partnership to Protect Coverage to urge President…
Read more
https://canceradvocacy.org/wp-content/uploads/Medicaid-Protect-Letter-Congress-Blog.png 628 1200 Kara Kenan https://canceradvocacy.org/wp-content/uploads/2020/06/NCCA-Logo.png Kara Kenan2023-03-24 15:51:462023-03-24 15:51:46NCCS Urges President Biden and Congress to Support and Protect Medicaid

NCCS Advocates for Access to DIEP Flap Breast Reconstruction Surgery

March 10, 2023
The National Coalition for Cancer Survivorship recently joined the Community Breast Reconstruction Alliance (CBRA), a group of patient…
Read more
https://canceradvocacy.org/wp-content/uploads/Diane-Heditsian-PBS-Newshour-DIEP-Flap.jpg 600 1200 NCCS Staff https://canceradvocacy.org/wp-content/uploads/2020/06/NCCA-Logo.png NCCS Staff2023-03-10 13:24:422023-03-10 13:28:53NCCS Advocates for Access to DIEP Flap Breast Reconstruction Surgery
NCCS Advocate Spotlight: Betsy Glosik, A Cancer Survivor's Journey Through Integrative Healing and Advocacy

Betsy Glosik: A Cancer Survivor’s Journey Towards Integrative Healing and Advocacy

March 8, 2023
For Betsy Glosik, the early 2000s brought one trauma after another. She lost her aunt to melanoma. Then, tragically she lost her 20-yr old daughter to a car accident. In 2003, after years of mentioning her concerns about a mole on her foot to her dermatologist, and repeatedly having her concerns dismissed, Betsy was diagnosed with melanoma...
Read more
https://canceradvocacy.org/wp-content/uploads/Betsy-Glosik-Advocate-Spotlight-Blog-Banner.jpg 600 1200 NCCS Staff https://canceradvocacy.org/wp-content/uploads/2020/06/NCCA-Logo.png NCCS Staff2023-03-08 12:55:132023-03-08 12:55:13Betsy Glosik: A Cancer Survivor’s Journey Towards Integrative Healing and Advocacy

Take Action

Make An Impact

We are relentless in improving the quality of care and life after a cancer diagnosis. Your support makes all the difference right now.

Make a Gift »

Join CPAT

The NCCS Cancer Policy & Advocacy Team (CPAT) is a program for survivors and caregivers to learn about pressing policy issues that affect quality cancer care in order to be engaged as advocates in public policy around the needs of cancer survivors.

Share Your Story

NCCS represents the millions of Americans who share a common experience – the survivorship experience – living with, through and beyond a cancer diagnosis.

STAY CONNECTED

Together we can improve cancer care for survivors! Sign up to be the first to know about cancer policy issues and ways to take action

  • This field is for validation purposes and should be left unchanged.

  • About
    • Our Mission
    • Our History
    • The 1986 Club
    • Our Team
      • Policy Advisors
    • Employment
    • Partnerships
    • Financial Information
  • Policy
    • Quality Cancer Care
    • Access to Care
    • Health Equity
    • Redefining Functional Status (RFS)
    • 2022 State of Cancer Survivorship Survey
    • 2021 State of Cancer Survivorship Survey
    • 2020 State of Cancer Survivorship Survey
    • Cancer Care Planning and Communications Act (CCPCA)
  • Get Involved
    • What is Advocacy?
    • Cancer Policy and Advocacy Team (CPAT)
    • Survivorship Champions
    • Subscribe to NCCS Updates
    • Elevating Survivorship
    • Survivor Stories
    • Cancerversary
    • State-Based Cancer Advocacy
  • Resources
    • COVID-19 Resources for Cancer Survivors
    • Survivorship Checklist
    • Cancer Survival Toolbox
    • Telehealth
    • Publications
      • Talking With Your Doctor
      • Self Advocacy
      • Employment Rights
      • Remaining Hopeful
    • Cancer Convos Podcast
    • Taking Charge of Your Care
    • Care Planning for Cancer Survivors
    • Tools For Care Providers
    • Order Our Resources
  • News
  • Events
    • Ellen L. Stovall Award
      • Nominations
      • 2022 Winners
      • Awardees
      • Reception and Sponsorship
    • Cancer Policy Roundtable (CPR)
      • Fall 2022 CPR
      • Spring 2022 CPR
      • Fall 2021 CPR
      • Spring 2021 CPR
      • Fall 2020 CPR
      • Spring 2020 CPR
    • Cancer Policy and Advocacy Team (CPAT) Virtual Symposium 2022
    • 2022 State of Survivorship Survey Results
    • Webinars
  • Contact Us

National Coalition for Cancer Survivorship
8455 Colesville Road  |  Suite 930  |  Silver Spring, MD 20910
877-NCCS-YES  |  info@canceradvocacy.org
Privacy Policy  |  Terms and Conditions

Copyright © 1995-2023 by the National Coalition for Cancer Survivorship
National Coalition for Cancer Survivorship, NCCS, Cancer Survival Toolbox, and related Logos are registered in the United States as trademarks of the National Coalition for Cancer Survivorship.

NCCS Comments on the FDA’s PDUFA Proposed Commitment Letter Fotolia 23428619 S e1461260836640 Cancer Moonshot Cancer Moonshot Blue Ribbon Panel Recommends Research to Minimize Debilitating...
Scroll to top
Download the Survey Report

"*" indicates required fields

Fill out the form below, and we’ll send the survey report, detailed presentation, and infographic to your email.
Name*
I am a...*
Select any/all that apply.
Consent*
By downloading the survey materials, you will receive updates and information from NCCS via email, which you may unsubscribe from at any time. Your information will never be sold to any third parties.
This field is for validation purposes and should be left unchanged.

Get Updates From NCCS

Be the first to hear about cancer policy and survivorship issues! Subscribe and receive the biweekly NCCS Health Care Roundup, invites to webinars and events, and more.

  • This field is for validation purposes and should be left unchanged.

Connect With Us

Twitter     Facebook     Instagram     LinkedIn     YouTube

Harmar Brereton, MD

Founder
Northeast Regional Cancer Institute

 

“Perhaps one of the most impactful collaborations in Dr. Brereton’s extraordinary career remains his early work and long friendship with Ellen Stovall. Through him, and in turn through the thousands of lives he has touched, Ellen’s work continues, and her mission lives on.”

—Karen M. Saunders
President, Northeast Regional Cancer Institute